Communications Channel

The Communications Channel is the appropriate means of contact for all members of Barberan and other interested parties (suppliers and collaborators) to report possible breaches of Barberan’s internal regulations or facts constituting a crime or administrative offence (hereinafter, “irregularities”) occurring within the organization.

This Channel is not the appropriate way to contact directly with the Data Protection Delegate, nor for the presentation of complaints related to Barberan products and services.

Barberan manages communications about irregularities through a software specifically enabled for this purpose to ensure compliance with applicable regulations. At the request of the interested party, complaints may also be submitted through a face-to-face meeting.

Notwithstanding the above, the interested party may contact the Independent Whistleblower Protection Authority. It is reported that in Catalonia, it is the Oficina Antifrau (https://www.antifrau.cat).

What can be communicated through the Channel?

Infringements of European Union law affecting the financial interests of the EU or affecting the internal market, such as public procurement; financial services and prevention of money laundering and terrorism; product, transport and food safety; environmental protection; radiation and nuclear safety; public health; consumer protection; protection of privacy and personal data; EU financial interests; infringements relating to the internal market, including competition rules, aid granted by the States, as well as those relating to the processing of corporate income tax.

Actions or omissions that may constitute a serious or very serious criminal or administrative offense or any violation of the rest of the legal system, provided that, in any of the cases, they directly affect or undermine the general interest, and do not have a specific regulation. In any case, the general interest will be understood to be affected when the action or omission in question implies economic loss for the Public Treasury.
Conduct contrary to Barberán’s internal regulations, such as the Code of Ethics.

How are incoming communications handled?

The management of the communications channel is carried out by a third party external to the organization who is responsible for receiving the communications, thus ensuring maximum respect for independence and confidentiality.

Barberan undertakes to send acknowledgement of receipt within a maximum period of 7 calendar days from the date of receipt of the communication.

The person in charge of the management of the Channel will analyze the content of the information and will assess its relevance, in an objective and impartial manner.

Once the investigation proceedings have been completed, the maximum period for responding to them shall not exceed three months from the date of receipt of the communication, except in cases of particular complexity that require an extension of the period, in which case, this may be extended up to a maximum of three additional months.

In any case, the reporting person may be asked for additional information.

Barberan has a registration system in which the communication received and the investigations carried out will be recorded, with restricted access to the Channel Manager, the Human Resources Manager and the Channel’s external manager.

Principles of action

Confidentiality: it is guaranteed that only the people who manage the Channel will have access to the communication and only they will communicate with the informant.

Anonymity: communications can be either with identification of the informant or anonymous.

Prohibition of retaliation and whistleblower protection: whistleblowers and persons collaborating in an investigation are protected against retaliation and may not be penalized or suffer any negative consequences for having reported an irregularity. This guarantee may be extended to persons related to the whistleblower.

Rights of the affected person: the person affected by the communication shall have the right to be informed of the actions or omissions attributed to him/her, and to be heard at any time. The presumption of innocence and the honor of the affected persons shall be respected.

Protection of personal data: the applicable data protection regulations shall be fully complied with. Personal data shall not be collected if it is not manifestly relevant to the specific information to be processed and, if accidentally collected, shall be deleted without undue delay. Measures will also be implemented to prevent unauthorized access.

Access the Communications Channel or by scanning this QR code: