Speak-up (whistleblower channel)

About this channel

EuroClinics operates a confidential internal reporting channel under Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law (the "Whistleblower Directive"), transposed into Spanish law as Ley 2/2023.

Anyone — employee, contractor, provider, patient, or member of the public — may use this channel to report concerns about possible breaches of Union or national law.

What can be reported

Fraud, bribery, or corruption.

Data-protection or privacy breaches.

Patient-safety incidents.

Discrimination, harassment, or unsafe working conditions.

Public-procurement, financial-services, anti-money-laundering breaches.

Anything else covered by the Whistleblower Directive (full list in Annex of Directive 2019/1937).

How to report

Email: whistleblower@euroclinics.net (only the Ethics Officer reads this inbox; not the wider engineering or operations team).

Web form: /speak-up/report — submit anonymously if you wish (no IP logging on this endpoint).

Phone: +34 91 123 4567 — confidential voicemail, transcribed by the Ethics Officer.

Postal: EuroClinics SL — Ethics Officer · PO Box 12345 · 28080 Madrid · Spain.

External channel: you may also report directly to the Independent Authority for the Protection of Whistleblowers (Autoridad Independiente de Protección al Informante) in Spain, or to your national equivalent.

Protection against retaliation (Art. 19)

EuroClinics absolutely prohibits any form of retaliation — dismissal, demotion, exclusion, loss of benefits, harassment, ranking change, contract termination, or any other detriment — against anyone who in good faith uses this channel.

Retaliation is a serious breach of our Code of Conduct and grounds for termination. Where retaliation occurs, we will reverse it and provide remedies.

Confidentiality of the reporter's identity is guaranteed and may only be disclosed where strictly necessary and proportionate as required by Union law (e.g. by court order).

Response timeline (Art. 9)

Acknowledgement of receipt: within 7 days.

Feedback on follow-up: within 3 months from acknowledgement.

Where a longer investigation is needed, you receive interim updates every 60 days.

Who handles your report

Reports are handled exclusively by the Ethics Officer (a senior partner at an external law firm), independent of EuroClinics management.

Reports involving senior management or board members are forwarded directly to the Board's Audit Committee chairperson.