This is a means of communication that IRB BARCELONA makes available to all those defined groups with access to this channel. This channel can be used to send communications referring to the areas of application of the Code of Conduct or any other internal policy and regulations applicable at IRB BARCELONA. A series of categories have been defined to help classify communications by area, thus facilitating their management and the completion of data collection forms.

According to point 1.2 of the Whistleblower Channel Policy

a) Conduct constituting a criminal offence or a serious or very serious administrative offence such as, for example, an offence of fraud, payment of an undue commission, non-payment of a tax or price fixing in a public tender;

b) Any act or omission of European Union law provided that:

i. concerns matters relating to public procurement; financial services, products and markets and the prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental protection; radiation protection and nuclear safety; food and feed safety, animal health and animal welfare; public health; consumer protection; protection of privacy and personal data; and security of networks and information systems.

ii. It affects the financial interests of the European Union, or

iii. It has an impact on the internal market, for example, infringements of EU competition rules and state aid. Incidents that are not included in this section, such as issues closely linked to human resources or personnel policies (e.g. holidays, remuneration, relations between employees, interpersonal conflicts, etc.), recommendations or suggestions not linked to regulatory compliance issues or to the provision of services by the entity, shall not be considered incidents to be reported through the Whistleblowing Channel.

No, this channel is not intended to handle urgent or emergency situations. You should contact the authorities or emergency services.

The person designated as responsible for the whistleblower channel and, in case of conflict, his or her replacement.

The Management Body of the complaints channel is composed of the director of management, the head of the finance department and the head of the legal department of IRB BARCELONA. The Management Body delegates to the head of the legal department of IRB BARCELONA the powers to manage the channel and to process the investigation files. If deemed necessary, the collaboration of external experts may be requested. The persons involved in the research are also subject to the duty of confidentiality and the privacy policy.

Yes. The Compliance Channel is open so that different actors in the business ecosystem can help detect unlawful activities. In any case, if it is a matter of complaints about the service offered, there are other channels available for submitting such complaints.

The Management Body of the complaints channel will communicate the acceptance of the complaint/consultation within a maximum period of 7 days. The deadline for resolving queries will be a maximum of 90 days, unless the complexity of the case requires a longer period of time, with justification.

The important thing is to act in good faith and that there is reason to believe that the facts reported are true. IRB BARCELONA does not expect the whistleblower to investigate the facts. The Complaints channel management body is responsible for this function. If the investigation concludes that no infringement has taken place, and that the complainant has acted in good faith, the complainant should not fear any retaliation.

Integrity, accountability and transparency are core values for IRB BARCELONA. As IRB BARCELONA members, we have an obligation to know and understand our Code of Conduct and other internal rules on the matter We also have a responsibility to report any possible non-compliance with our Code.

Unfortunately, for security reasons, only the whistleblower knows your access code and password. If he/she loses either of them, he/she will not be able to follow up the communication. This does not mean that the communication will not continue, but simply that he/she will not be able to see how it is progressing, or to provide more information if IRB Barcelona requires it.

In the reporting process you can decide whether or not to report your personal data. If you decide not to do so, you will need to set up your own monitoring through the reporting channel to see the progress and resolution. The channel will provide you with a username and password to access the progress of the report. The channel is independent of IRB Barcelona and does not record IP information from where you connect.

Some tips to achieve maximum anonymity, in addition to informing that the report is anonymous, are:

• Make sure that in the description of the communication you do not include information from which it is easy to identify you. The same applies to the documents you attach as possible evidence.
• Do not report from a computer connected to the IRB Barcelona network, including a mobile phone connected to the corporate wifi. Report2box does not log information, but before it reaches our systems it must pass through our own control systems such as proxy's or firewalls and there may be configurations that allow us to know which services you connect to.
• You can use the open source browser TOR, which anonymises the IP address.

Yes, you can review the Whistleblower Channel Policy here.

In accordance with current data protection legislation, IRB BARCELONA is responsible for the processing, management and storage of the personal data of all persons involved in queries and complaints. Both the Group and the external experts engaged comply with the necessary technical and organisational measures to guarantee the security of the data and to prevent its alteration, loss and unauthorised processing or access. The platform is designed to apply the current regulations on personal data protection, specifically, article 24 of Organic Law 3/2018 on the Protection of Personal Data and the guarantee of digital rights, which regulates reporting channels.

The complaints channel works on an external platform. This company receives the complaints and automatically sends them to the IRB BARCELONA for evaluation. The servers are located in DPCs in European territory. Your data is encrypted to avoid intrusion risks as much as possible.