Yes. The channel is open for different actors in the business ecosystem to help detect non-licit activities. In any case, if you are dealing with complaints about the service offered, there are other channels enabled to submit such complaints.

In accordance with the provisions of the current data protection regulations, Aldetall per un Comerç Competitiu SL with access to the Canal are responsible for the processing, management and storage of personal data of all persons involved in consultations and complaints. Both these and the contracted external experts comply with the technical and organizational measures necessary to ensure the security of the data and avoid its alteration, loss and unauthorized treatment or access.

The platform is designed to apply the current regulations on protection of personal data, specifically article 24, reporting channels.

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

● Make sure that the communication description does not include information that is easily identifiable. The same applies to the documents attached as possible evidence.

● Do not report from a computer connected to the company’s network, including a mobile connected to corporate wifi. Ithikios does not record information, but before reaching our systems you must go through the control systems themselves as proxy’s or firewalls and there may be configurations that allow you to know which services you connect to.

● You can use the TOR open source browser, which anonymizes the IP address.

Unfortunately, for security reasons, only the alerter knows your access code and password. If you lose any of them, you will not be able to keep track of the communication, that does not mean that the communication does not follow its course, simply that you will not be able to see how it advances, or provide more information if the company requires it.

No, this channel is not intended to manage emergencies. Contact emergency authorities or services in this case.

In the reporting process you can decide whether to report your personal data or not. If you choose not to do so, you must establish your own tracking through the reporting channel to see progress and resolution. The channel will offer you a user and key to access the progress of the complaint. The channel is independent of the company and does not record ip information from where you connect.

Yes. You can check the code of ethics from here.

Lo importante es actuar de buena fe y que haya motivos para creer que los hechos notificados son verídicos. El Equipo Directivo es quien debe asumir esta función. Si la investigación concluyera que no se ha producido ninguna infracción, y se concluyera que el notificante ha actuado de buena fe, éste no debe temer ningún tipo de represalia.

It is a means of communication that Fundació Casa Asil Sant Andreu de Palomar makes available to all defined groups with access to this Canal. Through this medium you can send communications referring to the areas of application of the Code of Ethics or any other internal policy and standard of application of the Foundation.

A number of categories have been defined to help typify communications by area, thus facilitating their management and the completion of data collection forms.

Those criminal offences established both in the Spanish Penal Code and in regulations of other countries in which Fundació Casa Asil Sant Andreu de Palomar operates, which are carried out by a legal representative or employee, in direct or indirect benefit of Fundació Casa Asil Sant Andreu de Palomar. Such as:

● Acts or omissions which may constitute infringements of European Union law

● Acts or omissions that may constitute a serious or very serious criminal or administrative offence. In any case, all serious or very serious criminal or administrative offences involving economic damage to public finances and social security shall be understood

The Management Team will communicate the acceptance of the complaint/consultation within a maximum of 7 days. The time limit for the resolution of the consultations shall be a maximum of 90 days, unless the complexity of the case requires a longer time limit in a justified manner.

The reporting channel operates on an external platform, https://ithikios.com. This company receives complaints and automatically sends them to the company for evaluation. ithikios servers are in CPD’s on European territory. Your data is encrypted to avoid the risk of intrusion.

The members of the Foundation’s Management Team begin the corresponding investigations. If necessary, the investigation is outsourced. Persons involved in the investigation are also subject to the duty of confidentiality and the privacy policy.

The Canal is managed by Regulatory Compliance specialists from Aldetall companies for a Comerç Competitiu SL with access to the Canal, with the collaboration, if necessary, of external experts.

Integrity, accountability and transparency are fundamental values for Fundació Casa Asil Sant Andreu de Palomar. We have an obligation to know and understand our Code of Ethics. We are also responsible for reporting any possible violations of our Code.