Whistleblowing Channel In compliance with Law 2/2023, of 20 February, on the protection of persons who report regulatory infringements and the fight against corruption, the VHIR is pleased to inform you that channels have been established to report any conduct or behaviour that takes place in the company which may constitute a crime, a serious or very serious administrative infraction or an infringement of European Union (EU) law. Two whistleblowing channels have been established: Internal channel: Managed internally by the VHIR, the internal whistleblowing channel can be accessed at the following link. External channel: Managed by the Anti-Fraud Office of Catalonia, the external whistleblowing channel can be accessed via this link. The whistleblower’s anonymity will be guaranteed when using these channels. They can opt to submit the report anonymously, which helps to strengthen the integrity of the VHIR. Who can report conduct subject to Law 2/2023 of 20 February? Individuals with employment-related or professional links to the VHIR may submit a report. In particular, this applies to the VHIR’s employees and former employees; suppliers; members of its Board of Trustees (including non-executive members); self-employed persons; any person working for or under the supervision of a contractor, sub-contractor or supplier of the VHIR; trainees; candidates in a selection process or pre-contractual negotiation; VHIR volunteers; or trainee workers employed directly by the VHIR or third parties who have had an employment-related or professional relationship with the VHIR. What must the report include? Reports must be truthful and therefore cannot contain any falsehoods. They must include the events giving rise to the report, alongside an explanation thereof. Any information considered relevant to the report may also be included. For non-anonymous reports, basic identifying details will be requested. This will allow us to request further information regarding the events, if necessary; to inform the whistleblower about the status of the procedure, if they wish to receive this information; and to arrange a personal interview with the person in charge of the Information System. Whistleblower protection All people submitting reports via the whistleblowing channel should be aware that their identity will not be disclosed, unless the matter reported is to be pursued through legal proceedings. I n this eventuality, the person’s identity will only be disclosed to law enforcement and/or judicial bodies. Nor may any form of reprisal be imposed on the whistleblower for reporting the events that are the subject of the report. Processing of the report Processing of the report The VHIR conducts its investigations with the utmost discretion and confidentiality, in accordance with current laws. Whenever possible, and without affecting personal information not in the public domain, the VHIR informs the whistleblower of the resolution. The VHIR informs the whistleblower when an investigation is closed. This will allow them share the information with another authority, should they wish to do so. The VHIR cannot impose any sanctions. If investigations reveal evidence of a criminal offence, the VHIR shall refer the facts to the Public Prosecutor’s Office or a judicial authority. If it is an administrative offence, it shall propose the application of a disciplinary sanction. It can also make recommendations for improvement in order to minimise the risk of future misconduct. If you have already reported the improper conduct to the security forces, the courts or the Public Prosecutor’s Office, you cannot submit a new report through the internal whistleblower channel set up by the VHIR. If you are aware that one of these authorities has already launched an investigation, you cannot submit a report for the same conduct. This is because the VHIR cannot perform functions corresponding to the judicial authority, the Public Prosecutor’s Office or the judicial police, nor can it investigate the same events that are the subject of their investigations. If the judicial authority or the Public Prosecutor’s Office initiates proceedings to determine the criminal relevance of events that are already being investigated by the VHIR, the latter must halt proceedings and immediately provide all the information at its disposal to the competent authority and support it in any way it can. Formulari Are you accessing this channel as a patient of Vall d'Hebron Hospital?* - Select -YesNo In this case, please fill in the form that you will find by clicking on the following link: https://www.vallhebron.com/en/contact Are you accessing this channel as a participant in a VHIR research study?* - Select -YesNo In this case, please fill in the form that you will find by clicking on the following link: https://vhir.vallhebron.com/en/form-suggestions-complaints-and-claims Would you like to file a new complaint or provide more information about a complaint you have already made?* - Select -I would like to file a new complaintI would like to provide more information about a complaint that has already been made Indicate the complaint number* Indicate what information you wish to provide* Attach the relevant documentation: Maximum 10 files.2 MB limit.Allowed types: gif, jpg, jpeg, png, bmp, eps, tif, pict, psd, txt, rtf, html, odf, pdf, doc, docx, ppt, pptx, xls, xlsx, xml, avi, mov, mp3, mp4, ogg, wav, bz2, dmg, gz, jar, rar, sit, svg, tar, zip. How do you want to submit the complaint?* - Select -Verbally (through a face-to-face interview)In written formBoth (in written form and through a face-to-face interview) Select how you want to submit the complaint* - Select -In written formBoth (in written form and through a face-to-face interview) Would you like to identify yourself?* - Select -I would like to identify myselfI would like to partially identify myselfI do not want to identify myself First name First surname Second surname Email address* Telephone number What is your relationship with VHIR? What is your relationship with VHIR? - None -EmployeeFormer employeeSupplierScholarship holderOther Provide your relationship with VHIR What is your relationship with the reported events / previous actions?* The reported events affect me personally or concern related persons (family members, friends, people in my professional environment). I became aware of the events in while carrying out my duties and functions. I have already appeared before other public bodies / institutions Have you appeared before other public bodies or agencies?* - Select -YesNo What action have you taken?* - Select -I have lodged an administrative appealI have lodged a legal appealI have filed a complaint with the Public Prosecutor's Office, the police or the courts Please explain the issue you wish to report (max. 280 characters)* Please provide as much detail as possible.* Attach the relevant documentation: Maximum 10 files.2 MB limit.Allowed types: gif, jpg, jpeg, png, bmp, eps, tif, pict, psd, txt, rtf, html, odf, pdf, doc, docx, ppt, pptx, xls, xlsx, xml, avi, mov, mp3, mp4, ogg, wav, bz2, dmg, gz, jar, rar, sit, svg, tar, zip. When did the events related to the issue take place? Where did the events related to the complaint take place? Would you like to receive communications informing you of the status of this procedure? (If you accept, you will receive communications via the e-mail address provided.)* - Select -YesNo If you file a verbal complaint in person, you should be aware that it may not be possible to guarantee your anonymity, but your confidentiality will always be preserved. An interview will be arranged so that you can meet in a private office with the person responsible for the Internal Information System. Please know that it is expressly forbidden for any kind of reprisal to be taken against you for the use of this internal communication system. This interview will be completely confidential. All information will be used only to carry out internal investigation processes and to establish the actions to be taken by the organisation in response to the reported events. Do you agree to opt for providing a verbal communication of the events?* - Select -YesNo Please indicate how we should contact you to arrange this interview. What is your preferred contact method?* - Select -TelephoneEmailNo preference Email* Telephone* I accept the conditions of use of this channel* Your complaint will be subject to an initial preliminary assessment to determine whether it falls within the scope of the objective and subjective competence of this channel, in accordance with the Internal Information System Policy of the Complaints Channel. Once this is verified, an assessment will be carried out to ascertain the truthfulness of the facts. If it is necessary to complete or clarify the data and/or information provided, and you have indicated your contact details, those responsible for the investigation will contact you. The investigations related to this channel are subject to the utmost reserve and confidentiality, and it is expressly forbidden for any kind of reprisal to be taken against those who report events using these channels. Should you accept the option of using the form, you will be informed of the result of the complaint, which cannot be appealed. However, if the person is not in agreement, he/she may use the channel provided by the Anti-Fraud Office of Catalonia. You should be aware that if you have filed a complaint a) knowing that the data and information you provide is untrue, or b) with the sole purpose of denigrating the persons or organisations being reported, you may be held liable in any resulting labour and/or legal proceedings. The VHIR cannot carry out the functions of the judicial authorities, the Public Prosecutor's Office or the judicial police. Therefore, if the events reported are or have been investigated by those authorities, the VHIR will suspend any actions it may have initiated, where appropriate. In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, Organic Law 3/2018, of 5 December, on the protection of personal data and guarantee of digital rights, and the rest of the regulations in force regarding the protection of personal data, we inform you of the following: The data controller of your personal data is the governing body of the VHIR: https://vhir.vallhebron.com/en/institute/governing-bodies/board-trustees. This governing body can be contacted through the postal address Passeig Vall d'Hebron 119-129, Edifici Mediterrània, Segona Planta, 08835, Barcelona. You can also contact us at the following e-mail address canaletic@vhir.org The contact details of the data protection officer are dpd@ticsalutsocial.cat. The purpose of processing your personal data is to manage the analysis and investigation actions necessary for processing complaints within the framework of the powers assigned to this channel. With regard to the legitimate processing of your personal data, said processing is necessary for the fulfilment of a legal obligation, a mission of public interest or in the exercise of public powers conferred on the data controller. Your data may be used by persons or institutions who, in accordance with current legislation and due to their functions, may be aware of the data obtained as a result of VHIR's investigative powers. Your identity can only be communicated when it constitutes a necessary and proportional legal obligation in the context of the investigation carried out by the competent authorities or as part of a legal proceeding. In the event that your data must be communicated to the previously mentioned institutions, you will be informed in advance, and informed of the reasons for sharing this data. Your data is processed as part of the processing activity "Analysis actions of the Complaints Channel" provided for in the controller's processing activity register. The international transfer of data should not be needed for processing, and neither should it be the object of automated individual decision-making, including profiling. The personal data collected for the aforementioned purposes will be kept for the time necessary to fulfil the purpose for which it was collected and to determine any possible liabilities that may arise from this objective. You may exercise your rights of access, rectification, deletion, limitation of processing, data portability and opposition in accordance with the provisions of articles 15 et seq. of Regulation (EU) 2016/679 of 27 April by sending an e-mail to lopd@vhir.org. You can send a complaint to the Catalan Data Protection Authority, particularly when you are not satisfied with the exercise of your rights, via the Authority's electronic address (https://apdcat.gencat.cat/ca/seu_electronica/index.html) or by non-electronic means (by post) to: c/Rosselló, 214, esc. A, 1r 1a, 08008 Barcelona or in person at the APDCAT's document entry register or at the entry register of any body of the Administration of the Generalitat de Catalunya or of the State, or by submitting the complaint to a post office in accordance with the applicable regulations.
