Frequently Asked Questions (FAQs)

What is an Ethics Channel?
An ethics channel is the company's internal tool that may be used by anyone to notify us any alleged illegal acts within the company or to its detriment and any alleged infractions of the Naturhouse Code of Ethics and Conduct or any other internal regulations. The ethics channel is also a conduit for people subject to the Naturhouse Code of Ethics and Conduct to ask any questions they may have regarding its content and interpretation.

Is it possible to submit information anonymously?
No. Whistleblowers must identify themselves with their full name and identity card or passport number and their nationality before they submit any information.

What are the guarantees provided to whistleblowers?
First, the company guarantees that any information submitted will be handled in a confidential manner. Whistleblowers' identities will be kept secret and their personal details shall only be revealed, if necessary, to the competent public authority to investigate the incident. Secondly, the company guarantees whistleblowers that they shall not be subject to any reprisals due to the submission of information. On the contrary, information provided in good faith is always welcome when it reveals irregularities taking place at the company. Whistleblowers also have the right to seek protection and guidance from the Ethics Channel Management Officer and/or the Ethics Committee, as well as advice on how to defend themselves against possible reprisals. Thirdly, whistleblowers are guaranteed that the information they submit shall be handled professionally by a specialist law firm.

Can I submit a report without any proof?
We will only admit reports based on the existence of evidence that an illegal act and/or an act that goes against the Code of Ethics and Conduct has been committed. Therefore, reports must be supported by proof, preferably document-based. Witness evidence is admitted -including the whistleblower's own testimony-, as well as pictures and sound and video recordings. It is important to highlight that whistleblowers must obtain any proof they submitt by lawful means.

What happens if a report is false?
All reports must be true and made in good faith and must comply with the Ethics Channel Rules and regulations. All users are warned that submitting false reports may constitute a crime of libel and defamation, described in articles 205 ss. of the Spanish Penal Code. The company may take legal actions against anyone who submits false information or in bad faith. In the case of false reports, the company may also reveal the whsitleblower's details to the accused so that he may take appropriate legal action.

Will the person accused be notified the existance of a report?
Yes. The law requires for the accused to be made aware that a report against him has been submitted and, therefore, as soon as proper checking and verification of the information has been made, and never later than three (3) months after the report, the company shall inform the accused of its existence. Nevertheless, it is important to stress that whistleblowers' details shall never be disclosed to the accused, except in cases of false reports.

Is there a time limit to check and verify a report?
A report, if admitted for processing, will lead to the opening of a case file to provide clarification regarding the reported incident(s). According to the Rules and Regulations of the Ethics Channel, the time period for processing the case may be no longer than three (3) months from the moment the case file is opened.

What consequences may an internal report bring if there is enough evidence of the commision of an act contreary to the law or the Code of Ethics and Conduct?
Following the company's checks and verifications, if there is enough evidence of the that an illegal act or an act against the Code of Ethics and Conduct have taken place, within the company or to its detriment, first, the company will immediately adopt all the necessary measures to bring these acts to an end or avoid them taking place. Then, based on the severity of the incident, the company may also decide to take the corresponding legal action against the person or persons allegedly responsible for said act(s), by presenting a claim, a report or any other legal action to the Courts, the Public Prosecutor's Office or the Police.

Privacy Policy

“NATURHOUSE HEALTH S.A.” (hereinafter referred to as “Naturhouse”), with address in Madrid, Calle Claudio Coello 91, 4th Floor (28006 - Spain), with NIF A-01115286, informs the users of the Ethics Channel (hereinafter referred to as the “Users”) that the personal data obtained through the Ethics Channel will be treated with the purpose of attending any queries or complaints made internally with regards to the alleged commission of acts contrary to the Law within Naturhouse or to its detriment and the breaches of Naturhouse’s Code of Ethics.

Lawfullness of processing personal data is based on the legitimate interest of Naturhouse in ensuring ethical and regulatory compliance within the organization, as well as in the consent of the Users with respect to any data they may provide.

The personal data concerned shall consist on the data included in the form or communicated by mail, as well as the the User's equipment IP data.

Data will be kept in the Ethics Channell only during the time necessary to decide on the appropriateness of initiating an investigation into the reported facts.

In any case, three (3) months after the data has been registered, it shall be removed from the complaint system, unless the purpose of the conservation is to leave evidence of the functioning of the legal entity’s crime prevention program.

Once the period mentioned in the previous paragraph has elapsed, the data may continue to be processed by the Naturhouse organ to which the investigation of the reported facts corresponds in order to process the internal investigation measures that may be necessary and, where appropriate, apply the disciplinary, contractual or judicial measures.

Personal data may be communicated to the Police, to other relevant organs of the Public Administration and to the Courts of Justice and other judicial organs.

Naturhouse undertakes to respect the confidentiality of the data included in the ethical channel and to use them in accordance with its purpose, as well as to comply with its obligation to store them and adapt all measures to avoid alteration, loss, treatment or unauthorized access in accordance with the provisions of current regulations. In particular, in accordance with the provisions of sections 7 and 9 of the Operating Rules of the Ethics Channel, Naturhouse will maintain the confidentiality of the data of Users who file internal complaints, preventing access to them by the alleged offenders.

Notwithstanding the foregoing, in the event that a report turns out to be false, the Users are informed that their data may be communicated to the alleged offenders so that they may, if they deem it appropriate, initiate legal actions against false accusation.

Personal data subjects may exercise, with respect to themselves, the rights recognized in General Data Protection Regulation and, in particular, the rights of access, rectification, deletion, opposition, portability, and restriction of processing.

The rights referred to in the preceding paragraph may be exercised by each data subject by email addressed to oficialdegestion.naturhouse@canal-etico.net or by ordinary postal mail addressed to:

LEXPIRIT, S.L.P.
C/ Impresores, 20
28.660 - Boadilla del Monte

Users and all other data subjects are informed that LEXPIRIT, S.L.P. is an external legal consultant of Naturhouse that holds the status of responsible for the treatment of the aforementioned Ethics Channel and that is entrusted to attend, on behalf of Naturhouse, the requests for the exercise of their rights by any affected data subjects.

In order for the data subjects to exercise any of the indicated rights, it will be necessary for them to include:

• a. Name and surname of the data subject, photocopy of his or her national identity document, or passport or other valid document to prove identity and, where appropriate, that of the person representing the data subject, as well as the document to prove such representation.
• b. Petition in which the request is specified.
• c. Address for the purposes of notifications, date and signature of the applicant.
• d. Documents to prove the request, if applicable.

Naturhouse also has a Data Protection Officer, with whom interested parties can contact by email for any incident related to their data at the following address: dpo@naturhouse.com

Finally, data subjects are informed that they have the right to present, if they consider it appropriate, a claim before the Spanish Agency for Data Protection (Agencia Española de Protección de Datos), which is based in Madrid (28.001), at calle Jorge Juan, no. 6

For a more complete and detailed information of their rights, it is recommended that the data subjects visit the website of the Spanish Agency for Data Protection or that they contact it through their citizen service, by calling 901.100.099.