Whistleblower Channel

ALDEBARÁN is fully committed to the highest ethical and Compliance standards in all its relationships and activities.

To ensure the maintenance of the Criminal Risk Management System, ALDEBARÁN Management Body has appointed and empowered a Compliance Responsible (CO), whose functions include the management of the Whistleblower Channel in accordance with C_PG007 Whistleblower Channel Management Procedure, which we invite you to consult.

ALDEBARÁN makes available to its members and any interested party, its Whistleblower Channel to report confidentially and even anonymously, any suspicious or knowledge of conduct, actions or omissions committed by a member of ALDEBARÁN in the exercise of their functions:

  • constitute infringements of European Union Law,
  • may constitute a serious or very serious administrative offence, including, specifically, those that may involve an economic loss for the Public Treasury and Spanish National Health System,
  • constitute breaches of the values, guidelines for action or standards of values, guidelines for action of conduct contained in the Code of Conduct of ALDEBARÁN and other internal regulations of ALDEBARÁN that is mandatory.

The aforementioned communications must be made using the following form.

The reporting person may also request a face-to-face meeting with the Compliance responsible (CO) through said from for the purpose of making a communication or complaint of the kind described above. In such case, the Compliance Responsible shall arrange such meeting within a maximum of seven (7) working days. In the event of a face-to-face meeting, and after obtaining the express and informed consent of the complainant regarding the processing of their personal data, the conversation held shall be documented in one of the following ways:

  • Recording of the conversation in a secure, durable and accessible format.
  • Complete and accurate transcription of the conversation. In this case, the complainant shall be given the opportunity to verify, rectify and agree with the transcript of the conversation by signing it.

Without constituting the preferred form for the submission of complaints and as an alternative to this internal ALDEBARÁN Whistleblower Channel, complaints may be submitted through external complaints channel to the Independent Authority for Whistleblower protection, to the competent administrative authorities, where appropriate, or to the institutions, bodies, offices and agencies of the European Union.

All complaints received will be entered into complaints register and each complaint will be assigned a unique reference number by which it can be identified throughout its processing.

All reports may be anonymous, for example, the identification of the person making the complaint is not mandatory but optional.

It is reported that only in the event that the informant or complainant provides an address, email or safe place to receive notifications, they will be noticed of the acknowledgement of receipt with a reference number of the complaint; ALDEBARÁN may request additional information if necessary and keep you informed of the admission or not to process and the corresponding resolution.

Complaints will be evaluated, investigated and resolved within a period not exceeding three (3) months from receipt of the complaint.

ALDEBARÁN states that the Whistleblower Channel complies with the following principles and offers the following guarantees, the specific development of which can be consulted in the Whistleblower Channel Management Procedure :

  1. Maximum confidentiality.
  2. Guarantee of the right to defence, presumption of innocence and the right to honour.
  3. Guarantee of the principle of evidence and contradiction.
  4. Management of conflicts of interest.
  5. Prohibition of reprisals, including threats and attempts of reprisals.
  6. Protection of personal data.

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