MINERVA INSIGHTS GROUP
Ethics Channel

Information Regarding the Existence of the Ethical Channel of Minerva Insights Group

With the aim of strengthening a genuine culture of compliance and acting consistently with its values and principles, Minerva Insights Group has implemented a confidential Internal Reporting System, known as the Ethical Channel. This channel constitutes the formal mechanism through which any individual who is part of the organization, or maintains a professional relationship with it, may securely, confidentially, and responsibly report facts that:

Constitute actual or potential risks, or for which there are reasonable grounds to suspect that they have occurred.

Could give rise to civil and/or criminal liability for Minerva Insights Group.

Represent breaches of the organization’s Code of Ethics.

Fall within the scope of the Protocol on Workplace, Sexual, or Gender-Based Harassment, as well as within the measures aimed at guaranteeing the real and effective equality of LGTBIQ+ individuals.

Provide indications or evidence of the commission of possible criminal offences within the company.

Furthermore, it is recalled that responsibility does not rest solely upon the person committing the infraction, but also upon those individuals who, having knowledge of improper conduct, tolerate, approve, or fail to promptly report it to their hierarchical superiors or to the manager of the Ethical Channel.

MINERVA INSIGHTS GROUP
Ethical Channel Policy

Scope

  • Any conduct classified as a criminal offence under the Criminal Code, especially those that may directly or indirectly benefit Minerva Insights Group.
  • Any acts or omissions affecting the European Union in the following areas:
    • Public procurement
    • Financial services, products and markets
    • Anti-money laundering and counter-terrorist financing
    • Product safety and compliance
    • Transport safety
    • Environmental protection
    • Radiation protection and nuclear safety
    • Food and feed safety, animal health and welfare
    • Public health
    • Consumer protection
    • Privacy, personal data, and network and information system security
    • Financial interests of the European Union
    • Competition and state aid within the EU internal market, as well as infringements of corporate tax law or practices aimed at obtaining tax advantages that undermine the purpose or objectives of such laws
  • Serious or very serious administrative breaches that cause financial harm to the Tax Authorities and/or the Social Security system. 
  • Any conduct or fact that may constitute harassment. These cases shall be governed by the provisions of the Anti-Harassment Protocol.
  • Any act of retaliation or negative consequence against employees or collaborators who have reported, in good faith, a potential misconduct or have participated in an investigation.

Features and Use of the Ethics Channel

  • Confidentiality guarantee: Access to the information received is restricted. All reports are taken seriously and handled by an independent third party to ensure total confidentiality. Anonymous reporting is allowed, although identification is encouraged to ensure effective protection and follow-up.
  • Good faith: Reports must be submitted responsibly and in good faith. Full certainty is not required, but honesty is expected.
  • Non-retaliation: No retaliation or adverse consequences shall occur against anyone who reports in good faith. On the contrary, such commitment will be positively valued. Any employee who believes they have suffered retaliation must report it immediately via the Ethics Channel.
  • Proportionality: All reports are treated equally, regardless of who submits them.
  • Decision-making: All decisions related to whether to initiate an investigation or close a report are documented and follow the established Ethics Channel Protocol implemented by Minerva Insights Group.
  • Deadlines: The protocol ensures compliance with applicable legal deadlines, depending on the nature of the report.
  • Data protection: Personal data is processed in accordance with applicable legislation.
  • Rights of the whistleblower and the investigated person: The protocol ensures the rights and duties of both parties are respected at all times.

Failure to report may be considered a very serious disciplinary offence.

Finally, we stress that the collaboration of all members of the Company is essential for the effective implementation of the criminal compliance program, whose purpose is to protect the legal entity and ensure its continuity and sound functioning, and, consequently, the well-being of all its employees.

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