I. Whistleblowing Channel and Queries
In order to provide guidance to those Active Subjects and collaborators of Nova Austral who have knowledge or suspect the occurrence of an irregularity or a breach of the Law, as well as with respect to any regulation or internal protocol issued by the Company, the latter has designed and implemented an internal whistleblower policy, which obliges the Active Subjects to report the above circumstances as well as any suspicion of conduct that may constitute a Crime or misconduct, informing the Company about these in order to review and address the situation, determining the appropriate courses of action.
In this regard, it shall be the responsibility of each of Nova Austral’s employees to consult in case of doubt regarding the application of any of the policies implemented by the Company, as well as to timely report any irregularities of which they may become aware.
Below are the specific procedures and policies implemented by Nova Austral with respect to its channel for complaints and consultations, as well as the anti-retaliation policies that must be applied with respect to employees, all of which are mandatory for the entire organization.
2. Procedure for filing complaints, contingencies and/or consultations
The Whistleblowing Channel is the means through which the Company’s employees and third parties can report breaches of the Law, Nova Austral’s internal policies and regulations, or any conduct that is unethical, contrary to the mission, vision or corporate values of the Company, as well as raise queries and concerns they may have regarding Nova Austral and its activities.
In any case, it should be noted that the Whistleblowing Channel is not an emergency service. Therefore, in the event of events or occurrences that represent an immediate threat to life, property or operations, the whistleblower should give the earliest possible notice to the respective management and the Compliance Officer, since reports submitted through this service do not receive an instant response, as they require an analysis that takes time to perform.
a. Filing of complaints and/or queries.
Any person may access the Whistleblowing Channel by entering the website https://pyme.ines.cl/pyme/formulario/, which can be found to facilitate access within the Nova Austral website: http://nova-austral.cl/contact/. Then, in the “Company Identification” option, you must select “Nova Austral”, which will allow you to access the queries and denunciations form implemented by the Company.
The complainant must accept the terms and conditions available on the Whistleblower Channel website.
Subsequently, he or she must complete the form that will be displayed, identifying, among other things, his or her relationship with Nova Austral and the type of denunciation and/or query he or she wishes to make.
The complainant must indicate his or her preference to remain anonymous or not, and then describe the complaint and provide the background on which he or she intends to base the complaint (including possible graphic or documentary evidence, if available), complying with all the fields in the form.
In order to complete the entry of the denunciation, the claimant must indicate a password associated with his/her complaint and/or consultation and, if he/she wishes to be contacted, he/she may also indicate an e-mail address.
Finally, he/she must select the “Send Complaint” button, after which a code associated with the respective denunciation or consultation will be generated.
If the denunciation or consultation is anonymous and no e-mail is entered, the claimant will not be able to recover his password, nor receive notifications in her/his mailbox, so it is recommended that you save the data of the denunciation, password and access.
b. Status review of the complaints.
In order to review and monitor the progress of the complaints and/or consultation process, as well as to provide additional information, the complainant may access the Whistleblowing Channel through the same web address indicated above.
To do so, the complainant must enter the code associated with his/her complaint or consultation and the password he/she has provided, and select the “Consult” button.
3. Procedure for investigating complaints or contingencies detected
The Compliance Officer will be in charge of receiving and analyzing the complaints or contingencies detected through the Whistleblowing Channel, and may take on these tasks directly or with the help of advisors external to the Company.
Each complaint received must pass a first filter to select the facts and/or situations that constitute it and, if its content is considered plausible, the procedure specially designed for the investigation and resolution of the complaints received that are admissible will be initiated, guaranteeing confidentiality, anonymity and communication with the complainant throughout the investigation process.
Additionally, complaints or queries may be made directly to the Compliance Officer, by e-mail to firstname.lastname@example.org.
The response time, as far as possible, should not exceed 90 days.
Once the investigations related to the reports received have been completed and if applicable, the Compliance Officer, together with the Chief Executive Officer, may take the disciplinary measures they deem appropriate, which shall be implemented by the respective Management, without prejudice to other civil and/or criminal actions that may be initiated against those responsible for the facts constituting the corresponding report. The Board of Directors shall be informed of all the above on a regular basis.