Introduction
Law 2/2023, of February 20, regulating the protection of people who report regulatory violations and the fight against corruption (hereinafter Law 2/2023) obliged municipalities with less than 10,000 inhabitants to have an Internal Alert System, as of December 1, 2023.
To ensure compliance with this deadline, in December 2023, the Bon Govern Working Group of the Open Government Network of Catalonia , with the collaboration of the Association of Microtowns of Catalonia and the Anti-Fraud Office of Catalonia in 2023, launched a campaign aimed at the local world for the implementation of the Internal Alert System, making available to them the two models of legal instruments prepared by the Open Government Network of Catalonia (XGOC), on the one hand, “Operating Instructions for the Internal Alert System of the City Council ...” and on the other, the “Operating Regulations for the Internal Alert System of the City Council ...” (hereinafter the Instruction and the Regulation); the files for approving the Instruction and designating the person responsible for the Internal Alert System, and the request form for the use of the consortium's technological tool AOC for the creation of the internal alert channel.
Currently, within the framework of the Open Government Network of Catalonia (hereinafter the Network), a model of support and advice to municipalities with less than 10,000 inhabitants is being analyzed for compliance with Law 2/2023.
In the meantime, this model of support and advice is being determined, the Network considers it necessary to develop a Guide aimed at those responsible for the Internal Alert System and the staff associated with the processing of communications. However, the Network's unifying capacity is highlighted, as it wants to highlight the large number of services already existing in the field of public administrations; especially with respect to the training and education offered by the AOC, regarding the implementation, assembly and use of the internal alert channel.
This guide is in no way a legal instrument, it is intended to be a tool with the necessary instructions and recommendations to implement the Internal Alert System.
Implement the Internal Alert System
For effective implementation of all elements of the Internal Alert System, the following actions must be carried out:
Raise awareness and train members of the organization
The Internal Alert System (SIA) is configured as a detection mechanism that allows the City Council to know about actions or omissions contrary to the law, act to defend the public interest, improve public management, demonstrate the commitment of the organization and public servants to transparency, honesty and integrity, and, ultimately, strengthen citizens' trust in public institutions.
In accordance with these objectives, the SIA is configured as a policy to promote alertness and protect the informant, which is why it is necessary for the organization to adopt the relevant measures, within a prevention framework, which begins with raising the awareness and awareness of its members, facilitating and offering adequate and sufficient training.
● Awareness-raising measures have been adopted within the organization.
● Appropriate training has been made available to members of the organization.
XGOC Recommendation : Awareness-raising, awareness-raising and training must be a constant action among the members of the organization. This awareness-raising action must be extended to third parties and the SIA must be disseminated once it is implemented.
We provide you with the following links where you can find training:
- Open Government Week: “ Against corruption and irregularities: internal alert systems in Catalonia ”.
Alert channel training given in collaboration with the XGOC and the AOC and convened periodically. Registration via form . - Session organized by the ACM, through the Transparency Foundation and Bon Govern, and in collaboration with the AOC Consortium and the Anti-Fraud Office “ impact of the Whistleblower Protection Law on local administration and the new obligations derived from the implementation of internal information systems in organizations .”
- OAC Webinar “ Alert channels and the protection of whistleblowers in the face of the new regulatory framework .”
- OAC Webinar “ Implementation of complaint channels in city councils. Experiences, recommendations and regulatory developments .”
- OAC Webinar “ EU Directive 2019/1937 on the protection of whistleblowers: progress in transposition and comparative view .”
- OAC Article “ The new European whistleblower protection directive: regulatory challenges and cultural change. ”
- Support Portal for the Alert Channel service , with a frequently asked questions area.