INTERNAL ANTI-FRAUD WHISTLEBLOWING CHANNEL AT ALICANTE UNIVERSITY LANGUAGE CENTRE
The anti-fraud Whistleblowing Channel is a secure electronic channel which allows the personnel from Alicante University Language Centre or any eternal persons to file formal complaints in accordance with Act 2/2023 of 20th February.
This channel adds procedures which guarantee the confidentiality of all information and offers a secure communication space in order to be in contact with the Alicante University Language Centre Anti-fraud Commission. It also allows the interaction between such Commission and the complainers in a confidential way. Communication anonymity in the is also assured, whenever the digital context in which communication guarantees it.
Regulations through which the internal anti-fraud whistleblowing channel is created and which regulates the internal channel of formal anti-fraud complaints of Alicante University Language Centre, approved b the administration Council on 14th June 2023.
Ir a la aplicación del canal de denuncias antifraude
- Any employee from Alicante University Language Centre.
- Institutions or companies which work or collaborate with Alicante University Language Centre whenever it is provided by the corresponding contract or agreement.
- Illegal use of destination of public funding.
- Subsidies’ diversion for other purposes for those they have been granted.
- Irregularities in public contacting.
- Arbitrary actions which determine an unequal access to public assets, subsidies and services.
- Conflicts of interest, breach of the right of abstention and breach of the incompatibility regulation.
- Accepting presents or indulgences from public servants.
- Using information obtained during public functions for private gain.
- Unjustified equity profit by the centre’s employees, derived from their responsibilities.
- The informer’s identification, which will have to be treated with due confidentiality, and which will have to comply with the applicable regulation on informers’ protection and personal data protection. Nevertheless, the channel will be able to receive anonymous communications, being the control, management and follow-up body obliged to commence the corresponding proceedings.
- Detailed description of the facto or suspicious situation, indicating, to the extent possible: what the potential or current irregular behavior or situation consists of; the involved persons; approximate dates of the event; means by which the possible illegal conduct has been occurred; affected activity area; possible economic impact; other possible impacts on Alicante University Language Centre.
- 1.-Once a communication has been submitted through the Channel, informers obtain an acknowledgement of receipt in which it is confirmed that the communication has been successfully performed. This acknowledgement of receipt includes an alphanumeric code with access to a confidential communication channel. This assigned code is the only possible access and informers must keep it. This electronic secure communication channel guarantees communication confidentiality and offers the possibility of preserving anonymity. Additionally, it allows informers to keep their collaboration with the whistleblowing channel’s managing body when verifying the facts.
The lack of an answer to the information requirements through the Anti-fraud Channel may imply taking no further action. - 2.- Once the communication has been made and if the informers have identified themselves, the managing body will provide them with acknowledgment of receipt within seven calendar days starting from the day after reception of the communication.
- 3.- If the communication does not clearly show the details, informers will be required to correct the detected errors through the channel or through the means the communication has been submitted within ten calendar days. If informers do not do so, the communication will not be accepted.
- 4.- Actions will extend to a maximum period of three months from the acknowledgement of receipt. This period of time could be extended to six months whenever necessary due to specific circumstances, in particular due to the complexity of the informed facts, which may justify such extension of time.
- 5.- After the facts are verified, the Channel will issue an assessment report, with the conclusions and proposals derived from them, which will be sent to the Managing Director and Vice-president of the Board of Directors of the Language Centre. Once there, recommendations will be made with public management improvement measures, or the corresponding body will be asked to start administrative proceedings in order to reinstate the altered legality, adopt sanctioning or disciplinary measures, or communicating the prosecution office the conducts which may be considered criminal offenses.
- 6.- During the whole process, measures will be adopted in order to guarantee both the informers’ integrity as well as the integrity of those affected by the facts or situations.
- 7.- If from the formal complaint or the proceedings’ content it could be deduced that the informer has acted in bad faith or has intentionally communicated false facts, possible responsibilities will be demanded, in accordance with any applicable provisions.
Informer have two options when making the communication anonymously:
- Using his browser, but facilitating his identification or contact data. IN this case, there is trace of the IP address from which the communication is submitted.
- Guaranteeing complete anonymity of the communication in the digital environment (also of the IP address, which can identify who is surfing the Internet), using an anonymization network. The most commonly used tool TOR network. As any other browser, to make use of TOR, the browser must be downloaded from the website https://www.torproject.org/es/download/
Tutorial video on how to download TOR:https://www.youtube.com/watch?v=JtSdVt2UmOU&ab_channel=UsoTor
The use of TOR to access the Channel is advisable and necessary when you are sure there is some risk since it guarantees the person’s anonymity when receiving the communication.
We remind you that it is not possible to access TOR from the University and other public institutions’ networks. To be able to use it, you will have to do it from a personal device in an external network.
We recommend your close the other browsers and application while making use of TOR.