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Internal Information System

The Internal Information System has been set up to comply with Spanish Law 2/2023 on the protection of persons reporting breaches of regulations and the fight against corruption [Ley 2/2023 reguladora de la protección de las personas que informen sobre infracciones normativas y de lucha contra la corrupción], also called the “Whistleblower Protection Law,” which is the result of the transposition into national law of Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law.

In order to adopt the principles established in this law, the public body that comprises the Museo Nacional del Prado has set up an internal information system (IIS) via a policy (only available in Spanish) that also establishes the rights of whistleblowers and regulates the Communications Management Procedure (only available in Spanish).

Whistleblowers who become aware of occurrences that could constitute a breach, as a result of employment at or a professional relationship with the organization, can use the following form to report said occurrences to the Museo Nacional del Prado.

ACCESS TO THE INTERNAL INFORMATION SYSTEM FORM (only available in Spanish)

What is the Prado’s Internal Information System?

The Internal Information System allows a person who has become aware—whether in the context of employment or a professional relationship—of information on the existence of a potential criminal or administrative breach or any other illicit behaviour taking place in the context of the activities performed by the Museo Nacional del Prado, to be able to report it or to inform the Museo Nacional del Prado of it.

What is the purpose and who are the intended users of the IIS as per the Policy on Whistleblower Protection and the Reporting System?

The IIS is intended for all professionals who become aware of a potential criminal or administrative breach, including public employees of the Museo Nacional del Prado, candidates for job postings, former employees of the organization, third parties and associated family members, and members of governing bodies and the Royal Board of Trustees. In addition to criminal or administrative breaches and violations of European Union law, whistleblowers can also report breaches of the Museo Nacional del Prado’s internal regulations.

More information is available in item 4 of the aforementioned policy as well as item 2 of the procedure.

What is the process for filing a report?

In line with the principles of the IIS (item 5 of the policy), which stipulate the confidentiality and safeguarding of whistleblowers, the applicable procedure provides an Internal Channel (item 4.1) for reporting potential breaches, in the form of a service external to the Museo Nacional del Prado.

The procedure states the minimum information required to submit a report as well as the deadlines applicable to sending confirmation of receipt, accepting or rejecting the report, internal investigation, final measures, disciplinary measures and the informing of the Public Prosecutor’s Office.

How is confidentiality guaranteed?

The confidentiality commitment applies to all communications received as well as the resulting investigations in order to prevent unauthorized access or undue disclosure. Access to information is restricted during both management and filing in order to prevent the disclosure of whistleblowers’ identity as well as to prevent penalties or reprisals.

In addition, the rights of both whistleblowers and affected or investigated persons are respected, and personal data protection rights are guaranteed (item 11 of the policy).

What are the key features of the Internal Reporting Channel?

  • Submission and tracking of a report
  • Anonymously written and voice (using a voice distorting feature) report
  • The details of the report’s content can be provided in various text fields and also attaching files in PDF, Excel and Word formats, as well as images (.png, .jpg, .webp, etc.). PowerPoint, HTML or Outlook (.msg) formats are not supported

Are there other channels for reporting or communicating possible breaches, apart from this Channel?

The Internal Reporting System (SII) refers to the Prado’s Internal Channel as the preferred system.

Management of the external channel at national level falls under the remit of the Spanish Independent Whistleblower Protection Authority (AIPI), via its online portal (only available in Spanish). This acts as a complement to the internal channel, ensuring the independence and autonomy required by European regulations.

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