Internal Channeling for Information Reception

This mechanism is designed for the management and channeling of information received from internal sources - employees, suppliers, contractors, etc. - or external sources - government agents, clients, or the general public - to avoid conduct that may be inappropriate, harmful, fraudulent, or criminal, in compliance with Constitutional, statutory, regulatory and/or jurisprudential provisions, both in Puerto Rico and the United States of America. Given that the sources of information of the conduct that is sought to be deterred may possibly be internal, frequently this internal source is in a better position to detect thereof; the objective of this compliance with information management and channeling is the protection of the source of information. In the event that the source of information of a complaint is internal (employees, suppliers, contractors, etc.), it is essential to protect the source (whistleblower) who reports such conduct from retaliation following the complaint.

It is necessary to encourage the reporting of such conduct given the impact that the crime or conduct that is being discouraged has on the company and society in general, both in monetary and demoralizing aspects. This objective cannot be achieved if the work team does not know that they will be protected from retaliation. If these whistleblower protection objectives are not achieved, such conduct will be difficult to detect and eliminate from the culture of the company and society.

Consequently, given the provisions of the rule of law of Puerto Rico and the United States of America, the Laws of Puerto Rico, - Law No. 115 of 1991 (P.R. Laws Ann. tit. 29, § 194 et seq.) - internal or external sources that make allegations are protected by these provisions.

Our policy with this information channeling mechanism, whether in the labor or contractual context, is to protect the source(whistleblower) that detects inappropriate, harmful, abusive, illegal, fraudulent, criminal activities, and that it is reported. In addition to protecting the source of the complaint, the objective is to channel the information in such a way that the necessary investigation can be concentrated in the appropriate context of an administrative or criminal investigation, and/or internal or external investigation, whichever that may be applicable; positively impacting our organization and society in general.