Policy of Use

1. Owner of the channel

In compliance with Law 34/2002, of July 11, on services of Fotowatio Renewable Ventures of information and electronic commerce, the identifying data of the owner of the complaints channel ethics.innovagrc.com are:

Fotowatio Renewable Ventures (hereinafter FRV) is the owner of this Whistleblowing Channel (hereinafter, the Channel). The registered office is located in Madrid, Calle Maria de Molina 40 - 5° and its VAT Number is ES B88276571, henceforth, FRV.

Access to this website, its content and its functionalities implies the express acceptance by the user of these General Policy of Use, which may be modified or replaced by the owner at any time and without prior notice.

FRV disclaims all responsibility for information outside of this website and that is not directly managed by its web administrator.


2. Conditions of use of the Channel

FRV has enabled this universal Whistleblowing Channel to allow anyone who has become aware of possible breaches of the Code of Ethics and Conduct, which may occur by employees, managers and collaborators of the company, to bring such circumstance to the attention of the ethical committee.

In the design and application of this Whistleblowing Channel, it fully respects the current legal framework and the fundamental rights of the people affected.

The Channel allows reporting both individuals and companies or organizations.

Identification and contact information must be provided.

A complaint may be filed through the prior registration of the user, using a valid email account.

Those registered users will be able to access the "My complaints" section, where they will view the details of each of the complaints filed on the channel. Likewise, they will receive real-time notifications in their email account about any change of status in their complaints.

All messages announcing non-compliance with FRV regulations or internal organization will be collected and processed.

The complaint registration process is as follows:

Communication of the complaint

Communication will be made from a web page published for the sole purpose of reporting channel server for FRV, by completing a web form.

Complaints will be received by the internal managers of the Channel designated for this purpose by FRV who are committed to preserving the identity and guaranteeing the confidentiality of the data corresponding to the people affected by the information provided, especially that of the person who reported the facts in knowledge of FRV.

Complaint content

The complaints received must contain the necessary data to be able to carry out the analysis of the reported facts. Thus, the received communications must meet at least the following requirements:

  • Description of the facts: Clear and detailed exposition of the facts.

  • Scope of the facts: place and time in which the event occurred or has been occurring, as well as the estimated monetary quantification of the damage.

  • Involved in the facts: Identification of the people involved in the reported behaviour or with knowledge of it.

  • Complainant data: Name and contact information of the complainant and his link with FRV to facilitate the analysis and follow-up of the complaint as well as, if deemed necessary, documents, files or other information deemed relevant for the evaluation and resolution of the complaint.

Complaint notification

Once you have sent the form, you will receive an email in the account specified in your user registration, confirming the registration of the complaint and with a link to the web application where you can view the data sent, as well as track it.

Complaint follow-up

The complainant will receive in his email any change in the status of his complaint, with a link that, again, will take him to the web form of the channel to be able to consult the details of the change of state.


3. Duty of information in the treatment of the complainant's data

  1. Responsible for the treatment and purposes
    • Notwithstanding the fact that by way of exception anonymous complaints can be accepted and exclusively in certain cases, in accordance with the legislation on Protection of Personal Data, it is reported that the transmitted data will be treated solely and exclusively in order to enable management of the Reporting and Fraud Prevention Channel, the implementation of which is mandatory for companies, in accordance with the provisions of Article 31 bis of the Penal Code, in order to comply with its Crime Prevention and Detection Models.

    • The Responsible for the Treatment of Personal Data is FRV.

    • Contact details of the Data Protection Officer (DPO):ethics@albacus.com

  2. System abuse and false reporting
    • Abuse of the system may lead to action against the perpetrator of the abuse. We inform you that the accusation and false complaints are constitutive of a crime in accordance with Art 456 of the Penal Code.

  3. No retaliation
    • Users of the system will not suffer any type of retaliation by FRV for the use of the Whistleblowing Channel and will not face any sanction if they use it in good faith.

  4. Rights in protection of personal data
    • The rights of access, rectification, cancellation, opposition, limitation, portability and forgetfulness will be exercised by the interested parties before the Head of Treatment of the Whistleblowing Channel, by writing, accompanied by a photocopy of the DNI or equivalent identification document, FRV, c/ Amistad 12 – 4° Getxo 48930 or by sending a message to the following email address: ethics@albacus.com, indicating in the 'Subject' line the right you wish to exercise.

    • In any case, the rights of cancellation, opposition and oblivion will be limited, insofar as an investigation or, where appropriate, legal or extrajudicial actions are being carried out, the facts denounced, and the identity of the complainant must be preserved.

  5. Whistleblower confidentiality
    • The system guarantees users who make any complaint to keep their identity confidential, provided that this is not required by the authorities or the report has been made with knowledge of its falsity.

    • Throughout the process of exchanging information with the channel manager, the complainant may be asked for his or her personal information. You will receive an email with a link to fill this information and send it voluntarily to the channel manager.