Reporting Channel

A. Introduction

The objective of this policy is to establish a system for the management of complaints that will allow the identification of irregular conduct at Fundació Cassià Just. In addition, it will allow the identification of areas for improvement in its internal management.
To this end, channels will be set up for the sending of complaints that can be used by all the groups of interest: employees, volunteers, donors, beneficiaries, suppliers, etc. of the Fundació Cassià Just.
It is considered that a denunciation implies manifesting the illegal, irregular or inconvenient state of any action carried out by Fundació Cassià Just.

B. Principles

Accessibility: the channel of communication will be clear and easy to access, through an e-mail established for this purpose and which will be public through the web page of Fundació Cassià Just.

Transparency: this policy will be public, as well as the e-mail established as a means of communication. Employees and stakeholders will be informed of the existence of this complaints channel.

Good faith: Complaints may be made anonymously. However, in order to be able to carry out an adequate follow-up, contact information will be requested in order to contact the whistleblower, it being the whistleblower’s decision to provide it or to make the report anonymously. In the event that the complaint is not anonymous, the Fundació Cassià Just undertakes not to take any disciplinary or legal action against the issuer or sender of a good faith complaint.
The Fundació Cassià Just reserves the right to take legal or disciplinary action against any employee or board member of the Foundation who retaliates against the sender of a good faith report.

Confidentiality: the identity of the person making the communication will be considered confidential information and may not be communicated without their consent. However, the details of the persons making the report may be provided to the administrative and judicial authorities whenever they are required to do so as a result of any proceedings arising from the subject of the report. This transfer of data to administrative or judicial authorities shall always be carried out in full compliance with the legislation on the protection of personal data.

Objectivity and impartiality: once a complaint has been received, the right to privacy, defence and the presumption of innocence of the persons who are the subject of the complaint shall be guaranteed.
The Board of Trustees will appoint one or several natural person trustees in charge of the management of the complaints, who will delegate to other trustees in the event that any of the complaints received may involve a conflict of interest. The designated members of the Foundation will hold a position other than that of President or Treasurer of the Foundation.

Efficiency: the processing of all applications will be carried out as before. However,
the Fundació reserves the right not to issue a response in the following cases:

a. Requests for confidential data: in the case of data regulated by law or that affect private agreements that require the protection of the persons and institutions involved.

b. Malicious requests that clearly violate the criterion of good faith in order to be disrespectful in content or form. When there are reasons or indications that the communication has been submitted in bad faith, it will be rejected and the sender will be informed of the reasons for the rejection. The Fundació Cassià Just then reserves the right to take disciplinary or other measures.

C. Procedure

Access:
The Fundació Cassià Just will set up an e-mail address, visible on the web page, for the reception of complaints.
This e-mail address will be accessible only to the persons designated by the Board of Trustees for the management of complaints, who undertake to treat the information received confidentially.

Management of the information:
A register will be kept of the complaints received showing the code assigned to the complaint, the date of receipt, the information contained and the date of response as well as any subsequent follow-up.

Analysis and resolution:

a- The person or persons designated by the Board of Trustees to manage the complaints receive the e-mails and send those requests for information or other questions that are not complaints to the administration department of the Fundació Cassià Just.

b. In the case of complaints:

– The persons designated by the Board of Trustees will be in charge of carrying out the investigation of the complaint received, for which they may interview as many people as they consider relevant in order to make an objective decision.
– The investigation procedure will always include a private interview with the person allegedly responsible for the conduct denounced.

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