Complaints channel

Don Bosco Foundation

The Don Bosco Foundation is governed by a Code of Ethics and has an anti-fraud and corruption Policy and a Code of Conduct for good treatment whose main objective is to promote corporate ethics by all people who relate to the entity in the exercise of their duties. your activity.

Therefore, those who are part of the entity must contribute to the achievement of its mission through behavior that consistently reflects its principles and values.

Consequently, the Don Bosco Foundation values very positively that people who relate to the entity, regardless of their relationship (contractual, volunteering, participants in projects or activities, suppliers or collaborators), report those behaviors that violate the Code of Conduct or the Anti-fraud and corruption Policy and that are irregular, illicit or criminal.

In this sense, we make a complaints channel available to all people so that they can report breaches of the Code of Conduct or any irregularities, illicit acts or criminal behavior that they detect within the entity.

This is a complaints channel that will process the content of the complaints to the corresponding Committee, according to the type of infraction, in accordance with the Regulation, thus guaranteeing the confidentiality of the complainant.

When should I report?

In accordance with the Regulations, through this confidential reporting channel, irregular, illicit or criminal conduct committed by a member of the Don Bosco Salesianos Social Foundation must be reported related, among others, to the following areas:

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Protection of minors and vulnerable people

Any form of violence due to action, omission or negligent treatment that deprives people, especially minors or those in vulnerable situations, of their rights and well-being, which threatens or interferes with their orderly physical, mental or social development, regardless of its form and means of commission, including that carried out through information and communication technologies, especially digital violence.

    Confidentiality of information

    Any unauthorized use of non-public information of the Don Bosco Foundation or its users.

    Sexual and gender-based abuse or harassment in the workplace

    Harassing behavior at work that involves sexual and gender-based harassment that undermines the dignity of workers.

    Abuse or harassment towards or between people related to the entity

    Any type of harassment or abuse that is not limited exclusively to the workplace and may affect volunteers, participants in projects or activities, suppliers or collaborators.

    Data Protection

    Inappropriate use or violation of the rights of personal information.

    Conflict of interests

    Personal situations or inappropriate relationships with third parties that may condition the correct performance of duties towards the Don Bosco Foundation by putting personal interests before those of the entity.

    Corruption

    Benefits to a public official to influence his decision, to obtain advantages or to compensate for an advantage obtained in the past, including facilitation or expediting payments; guarantee any benefits to persons who are not public officials to induce or reward improper performance of their function; the involvement of a user in a decision of the Don Bosco Foundation that entails a direct or indirect benefit for that user or for a person related to him or her.

    Workers' rights

    Behaviors that endanger the health and integrity of workers, or that generate situations of discrimination.

    Information resources

    Inappropriate use of Don Bosco Foundation computer equipment, unauthorized downloading of programs.

    Frauds

    Deception and omissions of relevant information to third parties.

    Anomalies in the origin and destination of financing

    Conduct that renders internal money laundering prevention policies ineffective, as well as the fraudulent obtaining, management and use of public aid or subsidies.

    Transparency in economic matters

    Concealment of assets, as well as systematic recording and analysis of commercial and financial transactions in breach of accounting regulations.

    download this documents

    Below we offer all the codes, policies and protocols that are related to this reporting channel.

    Protection Commission

    The protection commission will be permanently made up of the General Directorate of the entity, who presides over it, the person designated as responsible for protection, the management of the human resources area, the administration directorate and the project design and development directorate.

    Commission for Attention to Sexual and Gender-Based Harassment

    It will be made up of two technical people, in which at least one of them will be the person who manages the Human Resources area, and two others will be the legal representation of the workers. If this does not exist, the Don Bosco Foundation will designate one person from the direct care staff and another from middle management.

    Intervention in the event of a violation of the code of conduct

    FAQs

    These are the most frequently asked questions we receive. Please read them before contacting our entity.

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    What is a complaints channel?

    It is a mechanism available to any natural or legal person who has some type of relationship with the Don Bosco Foundation and through which an irregularity, illicit or crime that may negatively affect the Don Bosco Foundation in the provision of its services can be reported. It is a system that allows “users” to report confidentially, but not anonymously.

    Can complaints be made anonymously?

    Identification with your name, surname, National Identity Document/Foreign Identification Number/Passport Number and nationality, together with the other information that appears on the form does not undermine the anonymity of the complainants since the information is only accessible for people who belong to the protection committee and who are obliged to safeguard the privacy of the complainant. However, the form allows not to include information about identity, but reduces the possibility of clarifying and delving into the facts by not having a means of contrasting or expanding the information if necessary.

    What guarantees does the person who files a complaint have?

    The complaint will be made confidentially, that is, keeping the identity of the complainant secret, whose data may only be revealed to the Investigation Commission, with prior authorization from the complainant or, where appropriate, to the public authority competent for the investigation of the facts. Secondly, the Don Bosco Foundation guarantees the complainant in good faith that no retaliation will be taken against him for the simple fact of making a complaint.

    Can complaints be made without having evidence?

    Complaints must be made in good faith, they must be based on the existence of rational evidence of the commission of an illegal, criminal and/or act contrary to the Code of Ethics and, therefore, it would be recommended that they be supported by documentary evidence. Although testimonial evidence – including the testimony of the complainant himself – and instruments for reproducing words, images and sounds are also admissible. In any case, it is important to note that it is essential that the evidence has been obtained by the complainant lawfully.

    What happens if a report is false?

    Complaints must be truthful, must be made in good faith and must comply with the provisions of the Regulations of the complaints channel. It should be noted that the formulation of false complaints could constitute the crimes of slander and slander typified in articles 205 et seq. of the Penal Code. Don Bosco Foundation may adopt the appropriate legal measures against the person who makes a false or bad faith report.

    Will the accused be informed that there is a complaint against him?

    Yes. The law requires that the accused be aware that a complaint has been made against him and, therefore, as soon as the verifications have been carried out and the file has been processed and, in any case, within three (3) months following receipt of the complaint, the defendant will be informed of the existence of the complaint and a summary of it. Except in the cases provided for in the Regulation, the accused will not be given the identifying data of the complainant. As for the complainant’s data, they will be deleted within three (3) months after the pertinent investigations.

    What is the procedure once the complaint is filed?

    Once the complaint is received, a unique code is assigned and it is included in the Complaints Registry. Subsequently, and excluding the personal data of the complainant, the person responsible for the registry sends the Registry to the relevant Committee of the Don Bosco Foundation, which will be the body that makes a first assessment regarding the complaint. In case of the slightest indication of plausibility, an investigative commission will be appointed, which will access all the information in order to open a file that allows the pertinent decisions to be studied and adopted. The investigation regarding the reported facts may conclude with an exonerating resolution, if non-compliance with the law or the entity’s code of conduct has not been proven, or – otherwise – a conviction. The file will record the reasons for each decision.

    How are the reported events investigated and what consequences do they have?

    The procedure for investigating the facts is regulated by the internal regulations of the Don Bosco Foundation. In any case, the period for processing the file and adopting a decision in this regard may not exceed three (3) months from the date of its opening.

    If the investigation confirms the reported facts, firstly, the Don Bosco Foundation will immediately adopt all necessary measures to put an end to such acts or to prevent them from occurring. Subsequently, depending on the seriousness of the facts, the corresponding legal actions may be initiated against the person or persons allegedly responsible for them, including the internal disciplinary consequences of the Don Bosco Foundation and any others deemed pertinent.

    How is personal data processed within the framework of the Complaints Channel?

    All personal data provided for the purpose of the complaint will be treated in accordance with both Regulation (EU) 2016/679, of the European Parliament and of the Council, of April 27, 2016, relating to the protection of natural persons in respect of regarding the processing of personal data and the free circulation of these data, such as Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, for legitimate and specific purposes in relation to the investigation that may arise as a result of the complaint, will not be used for incompatible purposes and will be appropriate and not excessive in relation to the aforementioned purposes.

    complaint form

    If you wish to communicate a complaint to the Don Bosco Foundation, you can make it through the form that we put at your disposal.

    Independent Complainer Protection Authority

    If, despite having the commitment to protection and the possibility of anonymity in the Foundation’s Complaints Channel, you consider that you want to process your complaint through an external body, we provide you with the address of the Independent Whistleblower Protection Authority, A.A.I.

    This body is an independent administrative authority, with its own legal personality, full capacity to act publicly and privately, with administrative, advisory and sanctioning power.

    The objectives of the Independent Whistleblower Protection Authority are to guarantee the confidentiality and, where appropriate, the anonymity of whistleblowers.

    To process the complaint through the Independent Authority, access its web environment