Complaints channel

SUMMARY OF THE INTERNAL INFORMATION SYSTEM COMMUNICATIONS MANAGEMENT PROCESS

1. Access to the Internal Channel

An internal channel accessible through an electronic application is established for the submission of communications. This channel allows anonymous submissions and guarantees the confidentiality of the whistleblower’s identity when he/she is not anonymous. It also allows for dialogue with the whistleblower if necessary and respects the presumption of innocence and the honor of the persons concerned. Personal data is strictly protected, and any information suggesting a crime is immediately forwarded to the Public Prosecutor’s Office.

2. Acknowledgement of Receipt

The acknowledgement is automatic and provides an alphanumeric reference for follow-up of the communication. If the information is submitted anonymously or the informant does not wish to be contacted, the acknowledgement can be downloaded at the end of the communication.

3. Initial Analysis

The Head of the Internal Information System (IIS) assesses the information received to determine whether it falls within the scope of Law 2/2023. He/she may reject the communication, admit it for processing or file it.

4. Additional Information

The informant may provide new information during the process. The RSI may also request additional information for a proper assessment.

5. Completion of the Internal Process

The IHR, after studying the report, may file the report, refer it to the Public Prosecutor’s Office if there are indications of a crime, or communicate the information to the internal body or competent authority if the facts constitute a serious or very serious offense, always guaranteeing the confidentiality of the informant.

6. Registration and Internal Control of Information

Confidentiality and protection of personal data is guaranteed from the beginning. The system does not store personal data unnecessary for the processing of the information received.

7. Violations

The Independent Whistleblower Protection Authority is competent to hear offenses in the private sector, unless another authority is designated by regional regulations. Infringements are defined as retaliation against whistleblowers, breach of confidentiality guarantees, and disclosure of false information.