Whistleblower Channel
Whistleblower Channel
Last updated: [date]
At AlmaBrands, we promote a culture based on integrity, respect, transparency, and compliance with current regulations.
For this reason, we provide this Whistleblower Channel, through which employees, collaborators, clients, suppliers, contractors, and third parties related to Alma Brands can report, in good faith, facts or conduct that may be contrary to the law, our internal policies, ethical principles, or a respectful and safe work environment.
1. Purpose of the Whistleblower Channel
This channel is intended to receive, record, and manage reports related to facts that may affect integrity, legality, safety, transparency, or coexistence within Alma Brands.
Its goal is to enable the timely detection of risk situations and allow them to be reviewed confidentially, objectively, and in accordance with applicable regulations.
2. Who Can Submit a Report?
This channel may be used by:
- Employees.
- Former employees.
- Job applicants.
- Clients.
- Suppliers.
- Contractors and subcontractors.
- Service providers.
- Business partners.
- Any third party that has or has had a relationship with Alma Brands.
3. What Situations Can Be Reported?
For reference, reports may concern situations related to:
- Fraud, scams, or misappropriation.
- Bribery or corruption.
- Undisclosed conflicts of interest.
- Falsification of documents or records.
- Legal or regulatory non-compliance.
- Conduct contrary to internal policies or rules.
- Misuse of company resources, assets, or information.
- Breaches of confidentiality.
- Misuse of data or personal information.
- Discrimination.
- Workplace harassment.
- Sexual harassment.
- Workplace violence.
- Retaliation against people who have filed a report in good faith.
- Any other serious conduct that may affect Alma Brands or people related to the organization.
4. Situations Not Covered by This Channel
This Whistleblower Channel is not intended, in principle, for:
- Business inquiries.
- Quote requests.
- Customer service complaints.
- General questions about products or services.
- Administrative requests.
- Medical emergencies or situations of immediate danger.
If there is an immediate risk to a person’s life, physical integrity, or safety, we recommend contacting emergency services or the competent authorities directly.
5. Principles of the Whistleblower Channel
Reports will be received and managed, as applicable, in accordance with the following principles:
- Confidentiality.
- Respect and dignified treatment.
- Impartiality.
- Objectivity.
- Promptness.
- Protection of the privacy and reputation of the people involved.
- Prohibition of retaliation against those who report in good faith.
- The right of the people involved to provide information and be heard.
6. Identified and Anonymous Reports
Reports may be submitted:
Identified: providing the name and contact details of the reporting person.
Anonymous: without disclosing the identity of the reporting person, provided that sufficient information is given to allow a serious review of the facts.
Identified reports can facilitate the investigation process and make it possible to request additional information.
Alma Brands will endeavor to protect the identity of the reporting person and other people involved, in accordance with current regulations and applicable procedures.
7. Responsible Use of the Channel
This Whistleblower Channel must be used in good faith and responsibly.
Conclusive evidence is not required to submit a report. However, the reporting person is expected to act honestly and provide as much available information as possible.
Deliberately false or malicious reports, or reports made with the intent of harming another person, may result in the appropriate measures under current law and Alma Brands’ internal policies.
8. How to Submit a Report
Reports may be submitted through any of the following channels:
Web form:
[Form URL]
Email:
[almabrands@almabrands.cl]
Phone or WhatsApp:
[contact number]
In person or in writing:
[address or responsible department]
9. Recommended Information for a Report
To facilitate the review of the case, we recommend including as much information as possible, such as:
- A clear description of the facts.
- Approximate date or period when they occurred.
- Place where they occurred.
- Names of the people involved, if known.
- Related department, company, or project.
- How the reporting person became aware of the facts.
- Names of possible witnesses.
- Documents, emails, photographs, messages, files, or other supporting evidence.
- Contact details, if you wish to receive communications about the case.
The absence of any of this information will not necessarily prevent a report from being received, although it may limit the scope of the investigation.
10. Receipt and Review of Reports
Once a report is received, Alma Brands may:
- Record the case.
- Conduct a preliminary analysis of the information.
- Request additional information where possible.
- Refer the report to the responsible department or person.
- Initiate an internal review or investigation.
- Adopt preventive or protective measures where appropriate.
- Refer information to the competent bodies or authorities when necessary.
If a report falls outside the scope of this channel, it may be referred to the appropriate department or channel.
11. Workplace Harassment, Sexual Harassment, and Workplace Violence
Reports related to workplace harassment, sexual harassment, or workplace violence will be handled in accordance with current labor law and Alma Brands’ internal protocols.
Depending on the situation, protective measures may be adopted to safeguard the people involved during the procedure.
These measures may include, among others:
- Separation of physical workspaces.
- Temporary reassignment of duties or work schedules.
- Measures to prevent contact between the people involved.
- Privacy protection.
- Referral to the appropriate bodies.
- Other measures as needed depending on the seriousness of the facts.
Investigations related to these matters must seek to uphold the principles of confidentiality, impartiality, promptness, and respect for the dignity of everyone involved.
12. Confidentiality
Alma Brands will endeavor to handle reports and related information with the utmost discretion.
The information may be known only by the people who need access to it in order to analyze, investigate, or resolve the report, unless a legal, judicial, or administrative obligation requires its disclosure.
The identity of the reporting person, the reported person, witnesses, and others involved will be protected to the extent possible and legally permitted.
13. Prohibition of Retaliation
Alma Brands will not tolerate retaliation against people who:
- Submit a report in good faith.
- Participate as witnesses.
- Provide information.
- Cooperate in an investigation.
- Seek guidance about a possible irregularity.
Any retaliation related to the use of this channel may be investigated and result in the corresponding measures.
14. Rights of the People Involved
People involved in a report will have the right, as applicable, to:
- Be treated with respect and dignity.
- Have their information handled confidentially.
- Provide information and explanations.
- Be heard during the procedure.
- Submit documents or evidence.
- Have the investigation conducted objectively and impartially.
- Be informed of the measures or outcomes when legally appropriate.
15. Personal Data Protection
Personal data provided through this Whistleblower Channel will be used exclusively to receive, analyze, investigate, manage, and resolve reports.
It may also be used to adopt preventive, corrective, disciplinary, or legal measures when necessary.
This data will be processed in accordance with current Chilean law and the Alma Brands Privacy Policy.
16. Outcome of the Investigation
Depending on the information gathered, Alma Brands may:
- Close the report when there is insufficient information.
- Request additional information.
- Implement improvement or internal control measures.
- Adopt preventive or corrective measures.
- Apply disciplinary measures where appropriate.
- Refer the case to external advisors.
- Report the facts to the competent bodies or authorities.
- Take any appropriate legal action.
Where possible and legally appropriate, the reporting person may be informed of the general closure of the case.
17. Record Retention
Information related to a report will be retained for the period necessary to manage the case and comply with applicable legal, regulatory, labor, administrative, or judicial obligations.
Afterward, the information may be deleted, anonymized, or retained when required by a legal obligation.
18. Changes
Alma Brands may update this document when there are legal, regulatory, or organizational changes, or changes in how the Whistleblower Channel operates.
The current version will be available on our website and will indicate its last updated date.
19. Contact
For questions about how the Whistleblower Channel works, you can contact us through:
AlmaBrands / [full legal name]
Tax ID (RUT): [RUT]
Email: [almabrands@almabrands.cl]
Phone: [number]
Address: [address, district, region, Chile]