FERO Cancer Gala Madrid 2026
|
November 23
Book your place

Internal Information and Reporting Channel

1. Purpose of the Channel

FERO Foundation provides an Internal Information and Reporting Channel for individuals associated with the entity and its stakeholders to report possible irregularities, regulatory non-compliance, or conduct contrary to legality, ethics, or the Foundation’s operating principles.

The purpose of this channel is to reinforce transparency, integrity, accountability, and the prevention of irregular conduct within FERO Foundation.

The channel allows for reporting incidents related to FERO Foundation securely, confidentially, and, if desired, anonymously.

2. Who Can Use the Channel

This channel can be used by anyone who has had, has, or may have a relationship with FERO Foundation, including, among others:

  • Employees.
  • Volunteers.
  • Donors.
  • Beneficiaries.
  • Suppliers.
  • Collaborators.
  • Candidates in selection processes.
  • Individuals participating in calls, scholarships, events, activities, or projects linked to FERO Foundation.
  • Any other stakeholder related to the Foundation’s activity.

3. What Can Be Reported

Through this channel, facts or reasonable suspicions related to the following can be reported:

  • Serious or very serious criminal or administrative infractions.
  • Fraud, corruption, bribery, or misuse of funds.
  • Non-compliance with regulations applicable to FERO Foundation.
  • Conduct contrary to the Foundation’s ethical principles, transparency, or good governance.
  • Economic, accounting, tax, or administrative irregularities.
  • Undeclared conflicts of interest.
  • Non-compliance with data protection, confidentiality, or information security.
  • Discriminatory, abusive, intimidating conduct, or conduct contrary to human dignity.
  • Any other irregular conduct related to FERO Foundation.

The report must be made in good faith and based on truthful facts or reasonable indications.

4. What Should Not Be Reported Through This Channel

This channel is not intended for:

  • General inquiries about FERO Foundation.
  • Requests for information about projects, activities, scholarships, donations, or events.
  • Ordinary suggestions, comments, or improvement proposals.
  • Commercial claims or incidents not related to possible infractions.
  • Communications about entities or individuals unrelated to FERO Foundation, unless they are directly related to the Foundation’s activity.

For general inquiries, please use the contact information available on FERO Foundation’s contact page.

5. Submission Methods

Communications can be submitted through the form provided by FERO Foundation for this purpose.

[Insert button or link to the Reporting Channel form here]

The communication can be made identified or anonymously.

If the reporting person wishes to receive communications about the status of the processing, they may provide an email address, postal address, or other secure means of contact.

For anonymous communications, follow-up will depend on the technical possibilities of the system used and the information provided by the reporting person.

6. Recommended Minimum Information

To facilitate the analysis of the communication, it is recommended to include the following information:

  • Clear description of the facts.
  • Approximate date or period when they occurred.
  • Area, activity, project, or related individuals, if known.
  • Available documentation, evidence, or indications.
  • Any information that may help verify the facts.

Unnecessary personal data or information unrelated to the reported facts should not be included.

7. Channel Guarantees

FERO Foundation will manage this channel according to the following principles:

  • Accessibility: the channel will be available on the Foundation’s website.
  • Transparency: clear information will be provided about its existence, purpose, and operation.
  • Anonymity: anonymous communications will be permitted.
  • Confidentiality: the identity of the reporting person, affected persons, and any third party mentioned will be treated confidentially.
  • Good faith: communications must be made responsibly and based on true facts or reasonable indications.
  • Objectivity and impartiality: communications will be analyzed without conflicts of interest and with independence.
  • Efficiency: processing will be carried out with the utmost diligence and within the legally established deadlines.
  • Protection against retaliation: FERO Foundation will not tolerate any form of retaliation against those who report facts in good faith.

8. Confidentiality

FERO Foundation will guarantee the confidentiality of the identity of the reporting person and any other person mentioned in the communication.

Access to information will be limited to individuals strictly authorized for its reception, analysis, investigation, or resolution.

The identity of the reporting person may only be communicated to the judicial authority, the Public Prosecutor’s Office, the competent administrative authority, or in cases legally provided for.

9. Protection Against Retaliation

FERO Foundation expressly prohibits any act of retaliation, threat, unfavorable treatment, discrimination, labor, professional, or personal harm against individuals who use this channel in good faith.

This protection may also extend, where appropriate, to persons related to the reporting person, colleagues, family members, representatives, or associated entities.

This protection does not cover false communications made knowingly, in bad faith, or with abuse of right.

10. Rights of the Affected Person

Persons to whom facts communicated through the channel are attributed will have the right to the presumption of innocence, honor, defense, and to be heard at the appropriate time and in the appropriate manner to ensure the successful outcome of the investigation.

Communication to the affected person may be made when it does not compromise the investigation, the preservation of evidence, the confidentiality of the channel, or the rights of the reporting person.

11. Management Procedure

Once a communication is received, FERO Foundation will take the necessary actions for its proper management.

The procedure may include the following phases:

  • Registration of the communication and assignment of a case number.
  • Acknowledgment of receipt to the reporting person, when possible, within the legally established period.
  • Initial analysis to determine if the reported facts fall within the scope of the channel.
  • Archiving of the communication when it is manifestly unfounded, unrelated to FERO Foundation, or outside the scope of the channel.
  • Appointment of individuals responsible for analyzing or investigating the facts, ensuring independence and absence of conflicts of interest.
  • Request for additional information from the reporting person, when possible and necessary.
  • Conducting investigation actions proportionate to the nature of the facts.
  • Issuance of conclusions and proposal of measures, archiving, or referral to the competent authority when appropriate.
  • Communication of the completion of the procedure to the reporting person, when possible and legally appropriate.

12. Deadlines

When it is possible to contact the reporting person, FERO Foundation will send an acknowledgment of receipt of the communication within seven calendar days of its reception, unless this could jeopardize the confidentiality of the communication.

The maximum period for responding to investigation actions will be three months from the reception of the communication or, if no acknowledgment of receipt was sent, from the expiration of the seven-day period after the communication.

In cases of particular complexity, this period may be extended by up to an additional three months.

13. False or Bad Faith Communications

Communications must be made in good faith.

FERO Foundation may archive communications that are manifestly false, abusive, unfounded, or made in bad faith.

The use of the channel to knowingly make false reports may lead to appropriate legal or disciplinary measures.

14. External Reporting Channels

The reporting person may also resort to external reporting channels legally provided for before the competent authorities.

These channels include the Independent Authority for Whistleblower Protection, A.A.I., as well as, where appropriate, the competent regional authorities or bodies and the institutions, bodies, or agencies of the European Union.

FERO Foundation recommends preferentially using the internal channel when the infraction can be effectively addressed within the entity and there is no risk of retaliation.

15. Personal Data Protection

Personal data processed through the Internal Information and Reporting Channel will be managed by:

  • Controller: Fundació d’Estudis i Recerca Oncològica (FERO)
  • NIF: G62663661
  • Address: C/ Canàries 21, planta baja, 08017 Barcelona, Spain
  • Email: fero@fero.org

The data will be processed for the purpose of receiving, analyzing, processing, investigating, and resolving communications submitted through the channel, as well as for adopting necessary measures and complying with applicable legal obligations.

The legal basis for processing will be compliance with legal obligations applicable to FERO Foundation or, where appropriate, public interest and legitimate interest in preventing, detecting, and managing possible irregularities.

Identifying data, contact information, professional data, economic data, documentary data, information contained in the communication, data of affected persons, witnesses or third parties mentioned, and any other information necessary to investigate the reported facts may be processed.

Access to the data will be restricted to individuals authorized for channel management, the system administrator, individuals involved in the investigation, and, where appropriate, external advisors, data processors, administrative authorities, judicial authorities, or the Public Prosecutor’s Office.

Personal data not necessary to know or investigate the reported facts will not be processed. If irrelevant data is received, it will be deleted.

Data will be retained for the time necessary and proportionate to process the communication, investigate the facts, and comply with legal obligations. In no case will it be retained for a period exceeding ten years.

When a communication is not admitted for processing or does not lead to investigation actions, the data will be retained only for the period necessary to record the system’s operation, applying appropriate deletion or anonymization measures.

Interested parties may exercise their rights of access, rectification, erasure, objection, restriction, and other rights recognized by data protection regulations by writing to fero@ferocancer.org.

The exercise of these rights may be limited when necessary to preserve the confidentiality of the reporting person, avoid interference with the investigation, or comply with applicable legal obligations.

They may also file a complaint with the Spanish Data Protection Agency if they consider that the processing of their data does not comply with regulations.

16. FERO Foundation’s Commitment

FERO Foundation is committed to guaranteeing the integrity of the Internal Information and Reporting Channel, protecting reporting persons from retaliation, and ensuring objective, confidential, fair, and effective processing of received communications.

Last updated: June 2026.