Additional Provision on Data Protection Policy

Data controller

Sener Grupo de Ingeniería, S.A., with Tax ID Code (NIF) A-48914113, and registered address at Calle Cervantes 8, Gexto (Las Arenas), 48930, Vizcaya, will process the personal data to effectively manage your communication through the Ethics Hotline and, where appropriate, to investigate the facts arising therefrom.

We also inform you that the Sener Group has a Data Protection Officer, who can be contacted at any time via the email address [email protected].

Purpose and lawfulness of processing

The purpose of the management of the Ethics Hotline by Sener Grupo de Ingeniería is to process and investigate, in a confidential manner, the communications made regarding breaches of the law and/or internal regulations of the Sener Group.

The processing of personal data related to the Ethics Hotline is legally based on the following lawful grounds:

• Compliance with the obligations established in Law 2/2023 regulating the protection of persons reporting breaches of regulations and the fight against corruption.
• The consent granted by the informant for the processing of his or her personal data, where the informant has chosen to provide such data.

Data processed

Personal data processed will be those provided through the Ethics Hotline form: identification and contact details of the persons identified (persons involved, witnesses or third parties and, where appropriate, the informant), as well as additional data included in the communication (city, country, attached documents, etc.).

Users of the Ethics Hotline may maintain their anonymity by filling out only the required data, marked with an asterisk, necessary to investigate the reported event. Sener Grupo de Ingeniería guarantees the confidentiality and anonymity of the communications. If you would like to know more about the management of communications in the Sener Group, click here to view Standards for the Ethics Hotline Sener Group.

Data communications and international data transfers

The data provided will be processed and, where indispensable, disclosed to interested third parties, advisors or public authorities for the purposes of investigating and clarifying the facts reported, determining responsibilities, implementing corrective actions and, where appropriate, bringing the legal and/or disciplinary actions required before the bodies responsible in each case. Furthermore, the data subject to processing may be communicated to the other companies of the Sener Group, based on the legitimate interest in adequately managing the Ethics Line in a coordinated manner for all the companies.

Personal data related to the management of the Ethics Hotine will only be transferred internationally in the case of communications related to Sener Group subsidiaries located outside the European Economic Area. In these cases, the Sener Group has adopted appropriate safeguards for the protection of personal data, in accordance with current data protection regulations.

Data conservation

The personal data processed as a result of the management of the Ethics Hotline will be kept for a period of 3 months, from the receipt of the corresponding communication.

If it is decided to open an investigation, personal data will be kept for the time necessary to carry out the relevant enquiries and, subsequently, may be duly blocked for the corresponding legal periods for the sole purpose of responding to possible claims or legal requirements.

Data protection rights

Users of the Ethics Hotline may exercise their rights of access, rectification, erasure, opposition, limitation, portability and revocation of consent by sending an email to [email protected], indicating which right they wish to exercise and proving their identity.

However, the rights of access and opposition are subject to appropriate restrictions in order to effectively protect both the informant, the research itself and third parties involved in the research.

In addition, you may contact our Data Protection Officer, at any time via email [email protected], as well as file a complaint with the Spanish Data Protection Agency.