Whistleblower Channel

MCI Assist Channel is a fundamental tool for promoting an organizational culture based on transparency, ethics, and compliance. This channel provides all employees and stakeholders with a secure and confidential means to report any misconduct, policy violations, irregularities, or concerns related to the company.

IMPORTANT NOTICE
The whistleblower channel may ONLY be used by individuals who have the status of:EmployeesCollaborating freelancersShareholders, participants, and individuals belonging to the governing, managerial, or supervisory bodies of a company, including non-executive members.Any person working for or under the supervision and direction of contractors, subcontractors, and suppliersFormer employees, volunteers, interns, trainees, as well as those whose employment relationship has not yet begun.The whistleblower channel shall only be used for reporting possible crimes and/or breaches related to:
A. Any actions or omissions that may constitute infringements of European Union law provided that:
They fall within the scope of application of Union acts listed in the annex to Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law, irrespective of their qualification under domestic law.They affect the financial interests of the European Union as provided for in Article 325 of the Treaty on the Functioning of the European Union (TFEU).They affect the internal market, as provided for in Article 26(2) TFEU, including infringements of Union competition rules and State aid, as well as infringements of the rules of the internal market in relation to acts infringing corporate tax rules or practices aimed at obtaining a tax advantage which distort the object or purpose of the applicable corporate tax legislation.B. Actions or omissions that may constitute serious or very serious criminal or administrative offenses.
C. Breaches of:
• Policies and Procedures established in the Occupational Risk Prevention Plan and the Activity Prevention Planning.
• Data Protection Policies and Procedures.
• Policies and Procedures established in the Compliance Program.

This channel is available to all MCI Assist employees, as well as suppliers, customers, contractors, and other stakeholders who wish to report possible issues or inappropriate conduct within the company.

A wide range of issues can be reported, including but not limited to:

Fraud, corruption, or illegal conduct.Violations of internal or external policies.Conflicts of interest.Workplace harassment or discrimination.Threats to information security.Any other activity that may be detrimental to the company or its stakeholders.

The reporting process is simple and secure. Users can submit their reports anonymously if they wish, through an online form hosted on the MCI Assist website. They can also communicate directly with the Compliance Department or the Ethics Committee of the company via email at compliance@mcimanager.com.

Provide all relevant and detailed information possible for a proper investigation.Use clear and objective language when filing the report.Avoid making false or defamatory reports that may harm innocent individuals.

Confidentiality is crucial throughout the process. All reports will be treated with the utmost confidentiality, and measures will be taken to protect the whistleblower's identity as much as possible. Additionally, appropriate follow-up will be ensured for all reports submitted, ensuring that appropriate measures are taken to address and resolve the identified issues.