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.