Whistleblowing and transparency policy

Primus Ceramics, S.A. is committed to transparency and integrity in all its business activities, adopting practices that ensure high ethical and compliance standards.

This whistleblowing policy reinforces a culture of accountability and respect for the legal and ethical principles that guide the company, promoting a safe and trustworthy working environment.

This policy is available to all individuals, internal or external to Primus Ceramics, S.A., including employees, suppliers, partners, service providers and other stakeholders.

Reporting irregularities

Primus Ceramics, S.A. recognises the importance of providing a secure and accessible channel for employees and external parties to report suspected irregularities. The whistleblowing policy aims to:

• Facilitate the reporting of inappropriate or illegal conduct: Ensure that any suspicion can be reported simply and confidentially, allowing for a prompt and thorough investigation.
• Encourage early reporting: Promote timely communication of potential irregularities, enabling the company to take corrective measures quickly and effectively, while maintaining high standards of integrity and accountability.

Whistleblower protection

Primus Ceramics, S.A. is committed to protecting whistleblowers by providing a safe channel to report concerns and ensuring that reports can be submitted without fear of retaliation or adverse consequences.

The company guarantees confidentiality and protection of the whistleblower’s rights throughout the entire process, reinforcing its commitment to a safe and ethical workplace.

Rules and requirements for reporting

Primus Ceramics, S.A. believes that employees and external parties who suspect irregularities should be able to report them simply and securely.

This policy was created to ensure that all reports can be promptly and thoroughly investigated while guaranteeing the protection of the whistleblower.

Although the whistleblower is not required to prove the facts reported, they must present information that supports a reasonable suspicion, based on concrete facts or circumstances.

The policy encourages early reporting so that the company can respond swiftly with the appropriate corrective actions.

Reporting procedure

Reports must be submitted via the form available on the Primus Ceramics, S.A. website. The form allows the whistleblower to choose between remaining anonymous or providing identification.

The company ensures independence, impartiality, confidentiality, data protection, and freedom from conflicts of interest throughout the process.

Upon receiving a report, the whistleblower will be notified within seven days of its receipt and informed about the requirements and competent authorities involved.

All reports are reviewed, and an internal investigation is launched. If necessary, the case may also be referred to the appropriate authorities.

Within a maximum of three months, Primus Ceramics, S.A. will inform the whistleblower of the measures taken and the justification for those actions.

Reports will be recorded and retained for five years, or for the duration of any related legal or administrative proceedings.

Confidentiality and data protection

Primus Ceramics, S.A. guarantees the confidentiality of the whistleblower’s identity throughout the entire process.

Disclosure of identity will only occur if legally required or by court order. 

All personal data processing will comply with the General Data Protection Regulation (GDPR) and the company’s Privacy Policy, ensuring that the whistleblower’s rights are always protected.

Prohibition of retaliation

Any form of retaliation against the whistleblower is strictly prohibited.

Primus Ceramics, S.A. is committed to taking all necessary measures to prevent adverse actions against anyone who reports a suspected irregularity in good faith, ensuring a secure and retaliation-free reporting environment.

Further information

For more information about Anonymous Reporting, please contact us at: geral@primusceramics.com.

Primus Ceramics, S.A. reserves the right to update or amend this Anonymous Reporting Policy at any time. Any changes will be published on this page.

Date of last update: October 14, 2024