Clínica Girona whistleblower channel

Frequently asked questions

Here you can check the frequently questions in the anonymous reporting channel of Clínica Girona

1. What is the Clínica Girona Complaints Channel?

In compliance with Law 2/2023, of February 20, regulating the protection of people who report regulatory infringements and the fight against corruption, the complaints channel is a means of communication that Clínica Girona makes available to all those groups defined with access to this Channel. Through this means, communications referring to the areas of application of the Code of Ethics or any other internal policy and rules of application of Clínica Girona can be sent. A series of categories have been defined that help to typify communications by area, thus facilitating their management and completion of data collection forms.

Without prejudice to Clínica Girona's complaint channel, it is reported that there is also an external complaint channel, called the Independent Authority for the Protection of the Whistleblower, which, until regulations regarding the protection of people who alert 'regulatory violations in the field of the public sector of Catalonia, the Antifraud Office of Catalonia is assigned the functions that, in accordance with State Law 2/2023, of February 20, correspond to the institutions or the competent bodies of the autonomous communities.

2. Is there an ethical code in which to review conduct that can be denounced?

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

3. Is anonymity guaranteed in the complaint?

In the complaint process you can decide whether to report your personal data or not. If you decide not to, You must establish your own follow-up through the complaints channel to see the progress and resolution. The channel will offer you a username and password to access the progress of the complaint. The channel is independent of the company and does not record information on the IP from where it connects.

4. I have lost the access code to check the status of the complaint. What can I do?

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

5. How can I increase the anonymity when reporting?

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

• Make sure that the description of the communication does not include information with which it is easy to identify you. The same applies to documents that you attach as possible evidence.

• Do not report from a computer connected to the company network, including a mobile phone connected to the corporate Wi-Fi. Ithikios does not record information, but before reaching our systems it must go through the control systems themselves such as proxies or firewalls and there may be settings that allow us to know which services it connects to.

6. Can I report a labor situation if I do not belong to the company?

Yes. The channel is open so that different actors in the business ecosystem can help detect illegal activities. In any case, if they are claims about the service offered, there are other channels authorized to submit such complaints.

7. What types of crimes can I report?

Those criminal offenses established both in the Spanish Criminal Code and in European regulations, which are carried out by a legal representative or employee, for the direct or indirect benefit of the Clínica Girona group.

8. Who manages the complaints?

A manager of the entity, who initiates the corresponding investigations. If it is considered necessary, the investigation is outsourced, after notifying the accused and the complainant, except in the case of a criminal act that is referred to the public prosecutor's office. The persons involved in the investigation are also subject to the duty of confidentiality and the privacy policy.

9. When will I receive a response to my complaint or query? What is the resolution period?

The manager of the channel will communicate the acceptance of the complaint/query within a maximum period of 7 days. The term for resolving queries will be a maximum of 90 days, unless the complexity of the case requires a longer term for justified purposes.

10. What happens if, later, it is verified that the content of a complaint is false?

The important thing is to act in good faith and that there are reasons to believe that the reported facts are true. Clínica Girona does not expect the whistleblower to investigate the facts. The manager of the complaint channel is the one who should assume this function. If the investigation concludes that no infringement has occurred, and it is concluded that the notifier has acted in good faith, the notifier should not fear any type of retaliation.

11. If there is an emergency, should I use this channel?

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

12. How are personal data processed?

In accordance with the provisions of current data protection regulations, the companies that make up the Clínica Girona group with access to the Channel are responsible for the treatment, management and storage of the personal data of all the people involved in the queries and complaints. Both these and the external experts hired comply with the necessary technical and organizational measures to guarantee the security of the data and prevent its alteration, loss and unauthorized treatment or access. The platform is designed to apply current regulations on the protection of personal data, specifically article 24, on reporting channels.

13. Where is the platform that manages the channel?

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

14. Will the accused be aware of the complaint?

The complainant has the right to be informed of the actions or omissions attributed to him, in a time and manner that does not compromise the investigation of the facts, always respecting the confidentiality and anonymity of the complainant. It should be noted that the person reported will maintain the presumption of innocence until the resolution of the complaint.