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INFORMATION ON THE COMPLAINTS CHANNEL

OBJECTIVE OF THE COMPLAINTS CHANNEL

The main objective of the complaints channel is to facilitate the safe formulation, reception and processing of any communication on suspicious, irregular behaviour or breaches committed by employees, sales representatives, executives or business partners that may arise during the business activity of MOBILE LEAN, S.L., situational risks from exposure derived from interconnections with other organisations, public administrations and other organisations which, on this matter, favours environmental compliance based on the principles and values of MOBILE LEAN S.L.

In turn, the Law 2/2023, 20 February, regulator of the protection of persons who report regulatory infringements and the fight against corruption, is designed to protect informants, persons who detect and notify possible criminal violations, or serious or severe administrative violations.

SCOPE OF THE COMPLAINTS CHANNEL

What can be reported?

Any kind of well-founded act or incident may be notified through our channel that may contravene the principles and values of MOBILE LEAN, S.L. or entail an illegal act or contrary to current legislation, for example:

    • actions and omissions that may constitute criminal violations, or serious or severe administrative violations, in addition to crimes set forth in other special laws that apply, or may apply, in the future to MOBILE LEAN, S.L. 
    • criminal violations or serious or severe administrative violations that imply economic violation for HM Revenue and Customs and the Department of Social Security. 
    • breaches or conducts contrary to the principles, values and norms of conduct established in the Code of Conduct of MOBILE LEAN, S.L.
    • breaches or conducts contrary to policies, protocols, procedures, manuals, norms or internal controls established in MOBILE LEAN, S.L.

Who can report complaints?

Any third party that is internal or external to MOBILE LEAN, S.L. which has well-founded knowledge of some of the offences, irregularities or violations indicated in this policy:

  • all employees including temporary workers, interns and workers in training periods who carry out, or have carried out, their duties within MOBILE LEAN, S.L. 
  • candidates whose professional relationship has not initiated, providing that the information regarding violations has been obtained during the process of negotiation or pre-contractual relation.
  • shareholders, participants and persons belonging to the board of directors in MOBILE LEAN, S.L. 
  • business partners with whom MOBILE LEAN, S.L. has, or plans to establish, any kind of business relationship such as clients, suppliers, persons or companies to which they outsource activities, collaborators, consultants, representatives, agents, distributors, intermediaries, commission agents, investors, self-employed workers, etc. 
  • any person who works for MOBILE LEAN, S.L. or under their supervision, and the management of contractors, subcontractors and suppliers.

OPERATION OF THE COMPLAINTS CHANNEL

One of the main channels provided by MOBILE LEAN, S.L. for notifications regarding breaches or illegal activities described in this policy is through the complaints channel, which is accessible and operational 24 hours a day, 365 days of the year. The complaints channel is on our corporate website: https://www.mlean.com/, which facilitates the use of a safe environment and ensures that notifications will be processed objectively, independently, anonymously and confidentially.

The informant shall be informed of the state of their notification at all times, and in permanent contact with MOBILE LEAN S.L. through the company’s internal communication system.

In addition, MOBILE LEAN, S.L. provides the following means to enable written and in-person communications:

  • Postal address: Calle Duque de la Victoria, 5, planta 5, 47001 Valladolid (Spain)

In the case of written communications via the postal address above, the informant has the option to include their personal details (a name and a means of communication through which we can communicate (telephone or email)) and must include the date on which the notification is made, an approximate date of the incidents described and the most detailed description possible of the incidents reported.

In order to send a notification through our complaints channel on our website, the informant has two options: 

  1. to present an anonymous complaint: the informant is required to at least provide a title for the complaint, and to fill in the description field with information regarding the incident(s) on which the complaint is founded, along with documents attached to support the complaint; or 
  2. to present the complaint as an identifiable informant: together with the title of the complaint, a detailed description of the incident(s) and any supporting documentation deemed appropriate, the informant shall provide identifiable data (name and surname) and contact information (telephone number and email address).

MOBILE LEAN, S.L. ensures that the internal communication procedure is carried out confidentially by maintaining the identity of the participants in addition to the related information provided. 

In all cases, all obligatory fields indicated with an asterisk (*) must be completed in order to send a complaint. Furthermore, prior to sending a complaint form, the informant must confirm having read and agreed with the Privacy Policy in relation to personal data processing, which is necessary to initiate their notification.

Once the complaint is received, the informant will automatically receive an identification code through which they can track the state of the complaint at any time throughout the administration procedure. In the case of anonymous complaints, the identification code shall be the only means to access and track the complaint, and it is the informant’s responsibility to keep the ID code. In the case that it would be necessary to elaborate on the information to initiate the notification, MOBILE LEAN, S.L. may request further information through the internal communication service for administering complaints. MOBILE LEAN, S.L.

ADMINISTRATIVE PROCEDURE OF THE COMPLAINT

MOBILE LEAN, S.L. supervises the information contained in each complaint and analyses supporting documents in the cases that derive from this matter, MOBILE LEAN, S.L. shall request any additional clarification and/or proof related to the reported incident(s) from the informant through the internal communication service of the administration system for the complaints channel. Such proof includes documentary material in hard copy and/or electronic form related to the incident(s) reported of a professional nature at the company’s expense, and any other conduct from which necessary information may be obtained for the continuation of the complaints procedure.

Prior to the initiation of the investigation, there will be a verification to prove that there is no conflict of interests between any of the employees in the company who are responsible for investigating the notification. In the case that there is a conflict of interest, the conflicting employees shall be separated, and other employees shall be named to carry out the instruction in order to safeguard their independence.

Cases in which complaints have incidents described on the complaint form that may entail a reportable incident based on the description provided, shall be accepted to proceed with the process of the complaint. In this regard, notifications related to cases that do not equate to reportable incidents or lack sufficient motive and justification in order to verify such incidents shall not be accepted to process the complaint.

Irrespective of the admittance or not to process the complaint form, the informant shall receive an initial acknowledgement of receipt within the period of 7 calendar days from when MOBILE LEAN, S.L. received the complaint form through the complaints channel, in addition to information that derives from the course of the administration of their complaint form.

MOBILE LEAN, S.L. shall carry out investigation proceedings that correspond to obtaining all the information necessary in order to initiate the complaint, and the collaboration of other areas of the company, or authorised third parties, if necessary, shall be required and in compliance with the current applicable legislation.

Prior to the expiration of the 3-month period since the reception of the complaint, which may be extended up to another additional 3 months due to an especially complex case, MOBILE LEAN, S.L. commits to respond to the investigation proceedings related to the complaint. 

DATA PROTECTION AND CONFIDENTIALITY

Personal data processing that derives from the administration of the complaints channel is regulated by the provisions in the EU Regulation 2016/679 by the European Parliament and European Council on 27 April 2016, in the Organic Law 3/2018, 5 December on Personal Data Protection and Guarantee of Digital Rights, and in the Organic Law 7/2021, 26 May on Personal Data Protection processed for purposes of prevention, detection, investigation and judgement of criminal offences and execution of criminal sanctions. Should the information received contain special categories of data, such data shall be deleted, unless processing of the data is necessary due to reasons of a substantial public interest, as stipulated in article 9.2.g) of the General Data Protection Regulation, as set forth in article 30.5 of Law 2/2023. 

All the necessary information on the subject of data protection is in our website privacy policy: https://www.mlean.com/privacy-policy/

In line with the aforementioned, MOBILE LEAN, S.L. has implemented the necessary security measures in order to ensure the integrity and confidentiality of the information related to the complaints and maintains the conditions of protection for the informant and all those persons who may be affected by the complaint.

INDEPENDENT AUTHORITY FOR THE PROTECTION OF INFORMANTS

We inform you that, in the presence of the Independent Authority for the Protection of Informants, you may notify the commission of any actions or omissions included in this policy either directly, or via prior written communication through this channel. 

APPENDIX 1

A specific form is available for notifications made through our postal address. Click here.

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