Internal Information and Whistleblower Channel (Law 2/2023)
Welcome to Nuvolar’s Whistleblower Channel. This valuable resource gives you the opportunity to confidentially report any inappropriate, unethical or illegal conduct that you identify in our organization.
(Updated October 2025 — formerly “Complaints Channel”)
About This Channel
Nuvolar Group has established this Internal Information and Whistleblower Channel in full compliance with Law 2/2023, of 20 February, which regulates the protection of individuals who report regulatory and anti-corruption infringements.
This system provides a secure and confidential mechanism for employees, collaborators, suppliers, and other stakeholders to report any behaviour, action, or irregularity that may constitute a breach of law, company policy, or ethical standards.
All reports are handled with strict confidentiality, ensuring protection against retaliation and compliance with the General Data Protection Regulation (EU) 2016/679 (GDPR).
Responsible for the Internal Information System
The person Responsible for the Internal Information System (RSII) for Nuvolar Group is:
- Marketa Bartova
HR Manager – Nuvolar Group
ethics@nuvolar.com
This confidential mailbox is managed exclusively by the person Responsible for the Internal Information System and, in cases of conflict of interest, absence, or vacancy, by the external advisory firm Pedrosa Lagos, ensuring full independence and confidentiality in accordance with Article 8.3 of Law 2/2023.
You may also send a written report by post to:
Nuvolar Group – Attention: Internal Information System (RSII)
C/ Sancho de Ávila 105, 08018 Barcelona, Spain
(Confidential – To be opened only by the person Responsible for the Internal Information System)
What You Can Report
This channel is available to report any actions or omissions that may involve:
- • Breaches of law, regulations, or internal policies.
- • Corruption, fraud, embezzlement, or bribery.
- • Workplace misconduct, discrimination, or harassment.
- • Violations of health and safety or data protection obligations.
- • Conflicts of interest or misuse of confidential information.
- • Any other unethical or unlawful conduct within the organization.
Please note that personal grievances or HR-related disputes not involving legal or ethical breaches should be addressed through the usual internal HR channels.
How Reports Are Handled
- • You will receive an acknowledgment of receipt within 7 calendar days.
- • The report will be investigated confidentially by the RSII.
- • A resolution will be provided within 3 months, extendable to 6 months in complex cases.
- • Data will be processed only for investigation purposes and deleted when no longer necessary.
All investigations follow the procedure outlined in our
Internal Information System and Defense of the Informant Policy.
External Reporting Channel (AIPI)
If you prefer, you can also submit your report directly to the Autoridad Independiente de Protección del Informante (AIPI), the national authority responsible for external whistleblower reports.
The official website of the AIPI is https://www.proteccioninformante.gob.es.
The online reporting platform (external channel) will be available soon through that site.
The AIPI ensures full confidentiality and legal protection under the same framework established by Law 2/2023.
This external channel guarantees full confidentiality and protection under the same legal framework.
Privacy Notice
Personal data are processed in compliance with the General Data Protection Regulation (EU) 2016/679, Law 2/2023, and Spanish data protection law (LO 3/2018).
For more information, please see our
Privacy Policy for the Internal Information System.
Submit Your Report
You can submit your report securely through our internal reporting platform below.
