Internal Information Channel

Regulation establishing the internal information system of the Rey Juan Carlos University.

INTERNAL INFORMATION SYSTEM POLICY AND DEFENSE OF THE INFORMANT

The Rey Juan Carlos University is firmly committed to complying with and promoting the fight against corruption and the prevention, detection and reaction to the possible commission of crimes and infractions, in compliance with current regulations. Therefore, it subscribes to this information system and whistleblower defense policy in accordance with Law 2/2023, of February 20, regulating the protection of persons who report regulatory infractions and the fight against corruption with the aim of complying with, achieving, respecting and guaranteeing the highest standards of transparency, ethics and responsibility.

It also aims to strengthen the information culture, the integrity infrastructure of the entity and the promotion of the information or communication culture as a mechanism to prevent and detect threats to the public interest.

Since the Rey Juan Carlos University is subject to liability in accordance with current regulations, as it is an entity included in article 13 regarding obliged entities of the public sector, the entity has developed policies and protocols for the management, processing and diligence of the internal reporting or information channel and its successors.

WHAT IS THE INTERNAL INFORMATION CHANNEL?

Generally, staff are the first to notice an irregularity within the entity. Therefore, the internal information channel will be appropriate to report possible illegal or irregular activities and situations, without fear of reprisals and with the appropriate protection and guarantee measures.

Staff may make communications in writing or verbally, or both; although the internal information channel is the preferred channel for reporting actions or omissions that may constitute violations of European Union law or that may constitute a serious or very serious criminal or administrative offence; and in any case those that imply economic loss for the Treasury and for Social Security.

The Rey Juan Carlos University guarantees the confidentiality of informants by establishing the necessary measures. It will also guarantee the rights of the person or persons affected, mainly their presumption of innocence.

It is worth remembering that the best internal information channel cannot be effective if the organization does not have a culture of integrity and compliance that is truly implemented and actively lived in the organization.

WHAT IS AN ILLEGAL ACTIVITY?

According to the regulations, an illicit and/or illegal activity or behaviour refers to any actions or omissions that may constitute infringements of European Union law (and therefore fall into one of the types established by the Spanish Criminal Code) or affect the financial interests of the European Union, as well as actions 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 that imply financial losses for the Treasury and Social Security will be understood to be included.

PRINCIPLES OF ACTION

The principles of action on which this Internal Information System and Whistleblower Defense Policy is based are the following:

• Pursue the highest standards of transparency, ethics and responsibility by promoting zero tolerance for irregular actions and the fight against corruption.
• Comply with current legislation applicable to the entity's scope of activity and, specifically, its internal regulations.
• Promote staff involvement in the prevention and detection of illegal acts by training staff on the subject, as well as promoting the dissemination of the “Internal Information Channel” as a means of communicating conduct that may pose a danger to the entity, as well as any conduct contrary to the law.
• Create a figure to coordinate these actions, called “Internal Information System Manager”.
• Facilitate the actions of the Internal Information System Manager, providing him with the appropriate means and tools necessary to carry out his work in an optimal and efficient manner, with independence and acting autonomously and diligently.
• Respond promptly and effectively to a report of an alleged criminal act and proceed to investigate it, respecting the rights of both the informant and the affected persons and trying to avoid acting in a disproportionate and discriminatory manner when establishing any other type of measure.

Inform the competent authorities of alleged crimes, offering full cooperation in any subsequent investigations that may arise; the Systems Manager must immediately forward the information to the Public Prosecutor's Office when the facts could indicate a crime; or to the European Public Prosecutor's Office in the event that the facts affect the financial interests of the European Union.

EVALUATION AND REVIEW. CONTROL

The “Internal Information System Manager” has the power of initiative and control to evaluate and supervise the effectiveness of the Internal Communication Channel, to report information on its effective compliance and to propose the need for improvements if necessary. The “Internal Information System Manager” is responsible for controlling and supervising the correct implementation and compliance of the Internal Communication Channel as the maximum guarantor of the same.

Channel Manager: Prof. Mrs. Sara Núñez de Prado Clavell

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