Anti-Fraud Measures Plan (PMA)
With this Anti-Fraud Measures Plan (PMA) and its subsequent monitoring, CLPU aims to fulfill its obligations as the executing entity of publicly financed projects, including those from the Mechanism for Recovery and Resilience (MRR) Funds, as established by Regulation (EU) 241/2021 of the Parliament and the Council.
Anti-Fraud and Conflict of Interest Policy
The anti-fraud and conflict of interest policy represents the organization's declared intention to act in accordance with the principle of impartiality, maintaining an independent and unbiased criterion. It articulates commitments and conduct standards regarding conflicts of interest and fraudulent behaviors, promoting a true ethical culture in decision-making..
Ethical Code
The ethical code is a compilation of principles, values, and conduct norms that shape the culture of our organization. It reflects the governing body's expectations regarding the behavior of all CLPU members
Protocol for Conflict of Interest Management
This protocol establishes principles of action and appropriate measures to prevent, detect, and respond to potential or real conflicts of interest. It includes two models of Declaration of Absence of Conflict of Interest (DACI 1 and DACI 2) to be completed by participants in the procedures, including the contracting body, assisting bodies, and personnel involved in fund management or execution, as well as contractors and ultimate fund beneficiaries.
Protocol for Action in the Face of Suspected Fraudulent Acts and Disciplinary Regime
This protocol outlines the procedure for investigating allegedly fraudulent or corrupt conduct, as well as non-compliance with implemented measures and controls to prevent or minimize the risk of fraud or corruption. It regulates the steps to determine responsibility and the decision to be made in each case.
Guide to the Use and Management of the Whistleblower Channel
This guide provides a brief manual on the operation of the channel facilitated by the National Anti-Fraud Coordination Service (SNCA). It enables any citizen to report to authorities incidents that may constitute corruption, fraud, conflicts of interest, or irregularities related to CLPU's execution of projects funded by EU funds.
Complaints Channel
The complains channel is an internal information channel, which is part of the internal information system of the CLPU in compliance with the requirements imposed by Law 2/2023 on the protection of persons reporting regulatory breaches and the fight against corruption.