This document includes the Conditions of Use (hereinafter “Conditions”) of the Ethical Channel of the Ribera Salud Group (hereinafter “Ribera”). The Conditions may be modified at any time and the latest version published on the Ribera Website will be considered current.
By accepting this document, the Informant agrees that:
- Have read, understand and comprehend what is stated in the document.
- expressly accepts the terms of the document, the obligations that, as an Informant, are your responsibility.
What is the Ethical Channel?
The Ethical Channel is a computer platform established by Ribera whose purpose is to grant a adequate protection against reprisals that the natural persons who use it may suffer. Being this channel a medium secure, confidential and anonymous, so that actions or omissions of European Union Law, serious or very serious criminal or administrative infractions, violations of the Law on safety and health at work, breaches of the Code of Ethics, as well as any another internal standard of Ribera or the applicable legislation.
this channel not the right medium for the communication of issues such as claims or complaints of employees, as long as they do not imply a violation of the aspects mentioned in the previous paragraph. No communication whose content falls outside the scope of the Ethical Channel or that is made in disrespectful terms will be admitted.
The Ethical Channel is one of the elements of Ribera's Internal Information System (hereinafter "System") whose Policy is included in Annex I of this document.
Are there other means other than the Ethical Channel to make communications?
Yes, you can communicate directly to the System Manager by post, telephone call or by requesting an in-person interview, your details can be found in point 6 of this procedure.
Who can use the Ethical Channel?
All professionals linked by employment relationship of any kind with the companies managed by Ribera[1], including Directors, Administrators, Managers, temporary trainee personnel, statutory personnel, professionals with commercial ties and third-party professionals with whom Ribera interacts, job candidates, former workers and supplier workers.
What guarantees does the Ethical Channel offer?
The Ethical Channel has been configured in such a way that the informant is offered the following guarantees and rights:
What scope does the Ethical Channel have?
The Ribera Ethical Channel is applicable to the entities of the Ribera Salud group listed in Annex II.
Who is responsible for the system?
The System Manager:
- In Spain and Portugal: Helena Rivas Martínez (Compliance Director of Ribera).
In addition to through the Ethical Channel you can contact:
- E-mail: compliance@riberasalud.es
- Postal mail: Av. de les Corts Valencianes, 58, Piso 4, Puerta 08, 46015 Valencia, Spain.
- Telephone: in Spain: +34 638 170 086
Among its main functions are:
- Ensure the correct management and operation of the Ethical Channel and the System.
- Adequately protect the guarantees established in favor of the informant defined in the regulations.
These functions are carried out independently and autonomously with respect to the rest of the Ribera bodies, without receiving instructions of any kind in their exercise, and having all the personal and material resources necessary to carry them out.
How does the Ethics Channel work?
Below is a visual form of the operation of the Ethical Channel:
- Deadlines
From the date of receipt of the communication:
| AGENDA | Term | Description |
| acknowledge receipt | 7 days | Starting from the receipt of the complaint. Except in the case of anonymous postal communications, it will not be possible to issue an acknowledgment of receipt for not having data on the communicator. |
| Preliminary analysis | 1 month | In the event that an extension of the information has been requested from the communicator, the calculation of the period will begin again from the moment of receipt of the new information or from the end of the period for receiving the additional information (10 days). |
| Investigation Resolution | 3 months | As of the acknowledgment or, if an acknowledgment was not sent to the communicator, three months from the expiration of the seven-day period after the report was made. However, in those cases of special complexity, the maximum term to respond to the investigation may be extended up to a maximum of three (3) additional months. |
- Content of the communication
Communications made through the Ethical Channel have some required minimum fields to fill in the forms designed to facilitate the investigation of the reported facts.
The communication shall report actions or omissions that have been committed or are expected to be committed. The more information provided, the easier it will be to carry out the investigation and resolve the facts reported. may be refer those files that are relevant to the information and resolution of the case. The informant undertakes to provide truthful information and act in good faith.
The informant may identify himself or make the Communication anonymously. In both cases, the data that is incorporated into the Communication will be treated confidentially and the data protection regulations will be complied with.
The communications that are sent by the IT solution of the Ethical Channel, will generate an identification code in order to track the status of your Communication and if necessary provide additional information.
It is important that you keep the identification code in a safe place or medium and that you do not share it with third parties.
- Communication assignment.
The System Manager will assign a registration number and a person in charge within the Compliance Department to all communications received.
In the event that the complaint is directed against one of the members of the Compliance Department, or the latter could be a witness or interested party in the investigation, they will be excluded from participating in the preliminary analysis, as well as from participating in the Investigation Body. . The remaining members will identically follow the procedure defined in this document.
- Preliminary Analysis and Notification to Interested Parties
The person in charge to whom the communication is assigned must carry out a preliminary analysis of the information received, to verify if there are indications of veracity or credibility in the facts or the behaviors communicated. To do this, he will analyze the information received under the principles of veracity, clarity and completeness of the same, as well as the relevance of the facts communicated. In the preliminary analysis, it will be determined if the investigation is initiated, if the communication received is archived or if it is considered a false complaint.
In any case, communications that:
- From the information provided it can be deduced that it is not a breach of the internal or external regulations applicable to Ribera.
- They are the competence of another area or department of Ribera. In this case, the Responsible will limit itself to transferring the communication to said areas.
- The content of the communication appears irrelevant, lacks veracity, credibility or foundation.
- The information is now fully available to the public.
- The mere rumors.
- Do not provide new and significant information about facts already investigated.
Whatever the conclusion reached after carrying out the preliminary analysis, the interested parties must be reasonably notified within one (1) month from the receipt of the communication.
- Research
The person in charge of the System together with the person in charge of Compliance of each communication will be the competent body to designate the Instructing Body. This body may be individual or collegiate depending on the content and complexity of the communication, and will be made up of collaborators deemed necessary due to their knowledge of the subject matter of the investigation, who may be internal or external.
The Instructing Body, in the exercise of its investigative powers, will have unrestricted access to all information and to all organization personnel. Both the communicator and all other professionals within the scope of application of this procedure have the duty to collaborate facilitating the investigation of the facts, providing as much information as required.
A hearing will be given to all those affected and witnesses, including at least a private hearing with the person being investigated in which they will be informed of the facts that are the subject of the investigation, they will be invited to present their full version of the facts, it will be possible to provide the pertinent means of proof and the corresponding questions will be asked.
- Decision Making and Research Resolution
The Instructing Body will notify the corresponding Decision-making Body about the results of the Investigation Report, it must make a decision within the established deadlines, which must be duly documented.
The Decision-Making Body will be the one that, according to the regulations, is entrusted with the powers of supervision, surveillance and control over the matter under investigation.
Information Conservation
The information will only be kept for the period strictly necessary in compliance with the applicable regulations.
The registration of communications is not public, only at the reasoned request of the competent Judicial Authority, by means of an order, and within the framework of a judicial proceeding, the content of this may be accessed in whole or in part.
HSE Consultations
The purpose of the consultations is to raise existing doubts about the Code of Ethics, internal regulations and even applicable legislation when it is related to Compliance and affects professional performance.
Inquiries can be made through the following mailbox: compliance@riberasalud.es . It will not be suitable for the communication of issues such as claims or complaints from employees about their employment situation that must be processed through the established procedures.
The Compliance Department is in charge of analyzing the query and responding to it. It may require the collaboration of other competent areas of the Ribera Salud Group to resolve the queries raised. Once the query has been analyzed, a response will be issued within 1 month of receipt.
Spanish Independent Authority for the Protection of Whistleblowers (AAI).
When the events object of the communication have occurred in the Spanish companies of the Ribera Salud Group, the commission of any actions or omissions included in the scope of application of Law 2 may be reported to the AAI or to the corresponding authorities or autonomous bodies. /2023, of February 20, regulating the protection of people who report regulatory infractions and the fight against corruption.
Applicable Law and Jurisdiction
These conditions are governed by Spanish regulations. Any doubt that may arise in the fulfillment and interpretation of these, will be submitted to the Courts and Tribunals of the city of Valencia, with the parties waiving any jurisdiction that may correspond to them.
Last update: December 2023
Attachments
Annex I. Internal Information System Policy
Grupo Ribera Salud has a Internal Information System, designed in accordance with the requirements of the applicable regulations.
Said System is enabled to communicate, in safe way, infractions of European Union Law, serious or very serious criminal or administrative infractions, as well as possible breaches of the provisions of the Code of Ethics or any other internal or external regulation that affects the Ribera Salud Group.
Grupo Ribera Salud assumes the commitment to protect the people who make these communications ensuring, at all times, a diligent processing and the respect of the following guarantee:
- Confidentiality of all the people involved in a communication, as well as all the actions that take place during its processing.
- Absence of reprisals against people who communicate in good faith.
- Anonymity, without the need to provide any kind of data tending to the identification of the informants.
- Right to hearing, contradiction and presumption of innocence of the person affected by the communication.
- Treatment for Personal data according to the regulations in force.
In addition, it is guaranteed the right to the presumption of innocence and defense of person affected by the communication.
The Internal Information System of Grupo Ribera Salud is made up of the following: elements:
- Internal channel to carry out communications or Ethical Channel available on the corporate website.
- Responsible for the Information System: in charge of its management and processing of investigation files.
- Information management procedure: where the operation of the System is regulated in detail.
Failure to comply with any of the rules contained in relation to the System, without the need for any specific harmful result to be produced for Ribera Salud, could be considered conduct contrary to professional ethics, a breach of the internal rules of Ribera Salud and of the applicable legislation. Therefore, non-compliance may be subject to disciplinary measures.
Annex II. Ribera Salud Group companies included in the scope of the Ethical Channel
- First Health SLU
- Ribera Salud, SAU
- B2B Health, SLU
- B2B Integral Management SLU
- Hospital Povisa, SA
- Elche Crevillente Health SAU
- Torrejon Health, SA
- Ferrolanos Sanitary Projects, SLU
- Galo Saúde Parcerias Cascais, SA
- Ribera Salud Tecnologías SLU
- Home Medical Therapies, SL
- Hospital Polusa, SA
- Santo Domingo Clinic, SL
- Ribera Salud Infraestructuras SLU
- Virgen de la Caridad Medical Center, SL
- Virgen de la Caridad Caravaca Medical Center, SLU
- Practiser, SLU
- Immunological Center of the Valencian Community, SLU
- Ribera Salud SLU Projects
- Ribera Lab SLU
- Hospinet, SL
- Winning Security, SL
- Maintenance Services Prevencor, SLU
- Mar Menor Medical Center, SLU
- Águilas Polyclinic, SLU
- Virgen de la Caridad Medical Center Murcia, SLU
- Vega Media Clinic, SLU
- Home Help and Assistance Cartagena, SLU
- Virgen de la Caridad Alcantarilla Medical Center, SLU
- Our Lady of Sorrows Clinic, SLU
- Virgen de los Dolores Clinic, SLU
- Virgen de la Caridad La Unión Medical Center, SLU
- Virgen de la Caridad Medical Center Campoamor, SL
- Clinica la Flota, SLU
- Beauty and Health Virgen de la Caridad, SLU
- Northwest Health Center, SLU
- Virgen de la Caridad Mazarrón Medical Center, SLU
- Hyperbaric Medical Unit, SLU
- Digilab Dental, SL
- Prefor Salud, SLU
- Imatec Radiological Cabinets, SLU
- Lexdimur, SLU
- Ribera Medical SLU
- Diet and Cardiovascular Health, SL
- European Musculoskeletal Institute SL
- CK Hospital Covadonga SL.
Additionally, the Ribera Salud Foundation is also included in the Ethical Channel.
