Internal Reporting System Policy — Whistleblowing channel

1. Purpose, scope and core principles

This Policy explains how the Internal Reporting System (IRS / whistleblowing channel) of ATENEU INSTRUCTIU (tax ID G08730624) works, the protection of reporters and reported persons, and how to access it.

The channel allows members of the organisation and related third parties to report possible criminal conduct or serious administrative breaches in a professional context.

The Board of Directors appoints and removes the Internal Reporting System Manager (RSII), a natural person acting with functional independence. The specific appointment must be notified to the AIPI.

1.2. Material and personal scope

Reports must concern facts within ATENEU INSTRUCTIU that may constitute offences or serious breaches under Law 2/2023. Routine HR or catering complaints are excluded. Violence against minors is handled under LOPIVI (ClickEdu intranet).

1.4. Core principles

• Free access to the channel and this Policy.
• Independence and impartiality of the RSII.
• Confidentiality (need-to-know).
• No retaliation against good-faith reporters.
• This channel as the preferred internal means for Law 2/2023 matters.
• Trust through training and clear communication.

2. Submitting reports

Preferred internal means: secure website form; in-person meeting or call with the RSII by appointment (within 7 days of request). Anonymous reports receive a case code and PIN.

External means: Catalan Anti-Fraud Office, AIPI or other competent authorities. Anyone receiving a report elsewhere must forward it immediately to the RSII.

• Description and approximate date.
• Reason why it appears irregular.
• Persons responsible if known.
• Available evidence (lawfully obtained).
• Urgent risk if any.

2.3. Conflict of interest

If the report concerns the RSII, the Board shall appoint a substitute. Failure to abstain is a serious breach of this Policy.

3. Rights and obligations

The organisation protects good-faith reporters and respects the rights of reported persons (presumption of innocence, defence, etc.) under the internal procedure.

4. Handling procedure

• Acknowledgement within 7 calendar days unless confidentiality is at risk.
• Admissibility review and internal investigation.
• Conclusions and measures if appropriate.
• Maximum decision period: 3 months (+3 extension if complex).

5. Communication and training

This Policy is published on the website and communicated to staff. Interpretation queries (not reports): canal.denuncies@ateneuinstructiu.com.

6. Approval and review

Version 1.0 (June 2026): approved by the Board, effective from the RSII appointment resolution.

7. Personal data

Processing based on legal obligation (Law 2/2023). Controller: ATENEU INSTRUCTIU. Contact: administracio@ateneuinstructiu.com.

Definitions

• Reporter: person reporting in good faith within IRS scope.
• RSII: Internal Reporting System Manager.
• Anonymous report: no identifying data; follow-up via code and PIN.
• Good faith: reasonable belief; excludes revenge or knowing falsehood.