Organizational model and reporting whistleblowing

Médecins Sans Frontières Onlus adopted the Organization, Management and Control Model in accordance with Legislative Decree 231/01 by resolution no. 4/22 of the Board of Directors dated 18-19/02/2022.

The Code of Ethics defines the principles and values of the association that inspire medical-humanitarian action and that the Association undertakes to respect in its relations with those with whom it enters into relations to achieve its objectives.

The Organizational Model is a structured and organic system of internal, procedural, control and sanction mechanisms, suitable for preventing or reducing the possibility of the commission of the offenses provided for in Decree 231/01.

Doctors Without Borders Onlus, as part of its model and as required by Legislative Decree 231/01, has established a Supervisory Body in order to monitor the effective application, functioning, effectiveness and updating of the Organization, Management and Control Model and the Code of Ethics. The supervisory body is chaired by Lawyer Stefano Pazienza and can be contacted by e-mail by writing to [email protected].

WHISTLEBLOWING REPORTS

In compliance with Legislative Decree 24 of March 10, 2023, Doctors without Borders onlus provides the opportunity for employees, collaborators, volunteers and third parties who collaborate with the organization to report, even anonymously, offenses and/or violations of the code of ethics and code of conduct through an online platform that allows the report to be substantiated in a concrete way.

WHY REPORT

The term by which the discipline has come to be called is “whistleblowing”; a term of Anglo-Saxon origin “blow the whistle” referring to the action of the referee to report a wrongdoing. Reporting (whistleblowing), in this view, is an act to contribute to the emergence and prevention of risks and situations detrimental to the organization, its staff, member(s)/volunteer(s) and collaborators.

PROTECTION OF THE REPORTING PERSON

The report is handled in accordance with the principles of confidentiality and the possible identity of the reporter who does not choose anonymity, however, is not disclosed without his or her consent. Any personal data that may be present are processed in compliance with current Privacy legislation and kept for the period of time strictly necessary for the management of the report. Doctors without Borders onlus protects the reporting person from threats, retaliation and/or discrimination as a consequence of the report made.

PROTECTION OF THE REPORTED PERSON

In no case will sanction proceedings be initiated against the reported person solely on the grounds of the report, in the absence of concrete findings regarding the content of the report. The reported person will be notified of the outcome of the verification in the manner and within the time limits prescribed by law.

HOW TO REPORT

Reports can be submitted using the online platform, which is suitable for guaranteeing the confidentiality of the reporter’s identity by means of information technology.

The recipients of the report can be :

  • Supervisory body ([email protected]): in the case of offenses with respect to the crimes provided for in the organizational model
  • Ethics behavior committee ([email protected]): in the case of violations of the MSF international code of conduct transposed by MSF Italy.

As an alternative to the online platform, reporting can also be sent via email.

WHAT TO REPORT TO THE SUPERVISORY BODY

  • Violations of the rules and principles contained in the Organization, Management and Control Model pursuant to Legislative Decree no. 231/01;
  • Violations of MSF’s Code of Ethics in reference to the provisions of the organizational model ;
  • News related to the commission or attempted commission of crimes predicated on MSF’s co-responsibility
  • Violations of MSF procedures;
  • Criminal, civil, administrative, or accounting malfeasance;
  • Offenses within the scope of European Union or national acts as specified in the organizational model
  • Any behavior that is not legal and may compromise the integrity of MSF or its image.

WHAT TO REPORT TO THE ETHICS AND CONDUCT COMMITTEE

-Violations of the code of behavior, code of conduct, and code of ethics regarding the behaviors below:

  • Abuse of Power
  • Discrimination
  • Racism
  • Sexual abuse and harassment
  • Sexual exploitation
  • Bullying and mobbing
  • Assaults
  • Abuse of power
  • Inappropriate Behavior and Communication

-Abuses related to the reported internal case management process such as retaliation, interference, false (malicious) reporting, misrepresentation, and breach of confidentiality.

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PROCEDURES AND DOCUMENTS

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