Internal information channel

This internal information channel is designed under the protection and full compliance with the provisions set forth in the Plan for the Prevention of Criminal Risks of Sarton Dominicana SAS, particularly taking into account the provisions established in the Constitution of the Dominican Republic and good governance practices in comparative law, especially Directive (EU) 2019/1937, of 23 October 2019, on the protection of persons who report breaches of EU law and Law 2/2023, of 20 February, regulating the protection of persons who report regulatory and anti-corruption breaches in Spain. The main purpose is to protect people who report certain facts or conduct that may involve criminal infractions or offences of the legal system (in the terms that will be described in the material field), protection that in turn is proclaimed as a fundamental element for the detection and prevention of their own behaviors.

By virtue of the provisions provided, the informants (Whistleblowers) without the protection granted by the law, in many cases, do not report the information for fear of being subject to retaliation and, in turn, the conduct they intended to denounce would not be detected.

Therefore, in accordance with the provisions of article 169, paragraph I, of the Constitution of the Dominican Republic, in the exercise of its functions, through the Public Prosecutor's Office, it shall provide for the protection of victims and witnesses and defend the public interest protected by law.

It is important to protect persons who, in an work or professional context, detect serious or very serious criminal or administrative offenses and report them through the mechanisms regulated therein, extending the material scope of the Constitution regarding the protection of persons from infringement of the national legal system, but limited to criminal and serious or very serious administrative offenses to allow both internal and external information channels to concentrate their investigative activity on those violations that are considered to have the greatest impact on society as a whole.

It is essential to protect the persons who inform, and to provide the required security for the informant, security without which the informant would not, in many cases, communicate the events or behaviors in which they are supposed to intervene. It is worth transcribing: “The good faith, the honest conscience that had happened or can happen harmful and serious events constitutes an indispensable requirement for the informant’s protection. That good faith is the expression of their civic behavior and that is opposed to other actions that, on the contrary, results indispensable excluding from the protection, those as the remission of false or misrepresented information, as well as those that have been obtained illegally.” The configuration of the Internal information System must meet certain requirements, among others, the affordable use, the confidentiality guarantees, the correct practice of the follow up, investigation and protection of the informant, requirements of which a specific reference in sections will be made that are developed or can have singular incidents.

The object and nature of the internal information system is to quickly deal with any sign of a serious or very serious criminal or administrative infraction against the general interest, searching the eradication and/or prevention of any fraud, getting ahead exponentially with the knowledge that someone is committing irregularities and has de advantage that it can be stopped as swiftly as possible, avoiding major damages that would exist on a late detection.