Transparency of Next Fertility
All Next Clinics staff must uphold these high standards and have the right and duty to raise concerns, at the earliest reasonable opportunity, about malpractices within the Next Clinics Group.
Hence, the various companies within the group, including Next Fertility, have a transparency channel through which to report irregular or unlawful actions that violate current legal regulations, the Code of Conduct, or the Anti-Bribery and Anti-Corruption Policy of the group, or any other internal regulations of the Next Clinics Group.
Other matters, such as complaints about the received service, labor issues, or the removal of personal data, will not be handled through this channel but should be directed to the corresponding channels.
Objectives of the Transparency Channel:
- Detect irregular conduct
- Promote transparency
- Protect whistleblowers
- Ensure confidentiality
- Maintain an ethical corporate culture
If you have information and a reasonable suspicion that work-related misconduct has occurred in connection with the activities of Next Fertility Nordic Clinic, you have the right and the opportunity to report it safely and confidentially.
How to report
- First, report the matter to your direct manager.
- If this is not possible, please submit your report by email to: vihje@ivfnordic.com
Who can submit a report?
Reports may be submitted by anyone who has information about a suspected violation, including:
- Employees working under an employment contract or any other contractual arrangement with our clinic.
- Self-employed individuals providing services to our clinic.
- Members of our clinic’s management or supervisory bodies.
- Volunteers working at our clinic.
- Interns, trainees, and medical residents.
- Individuals involved in pre-contractual negotiations or otherwise preparing to enter into a contractual relationship with our clinic.
- Former employees whose employment relationship with our clinic has ended.
- Individuals working for one of our contractual partners in any of the capacities listed above.
- Any other person who has information about an actual or attempted work-related violation.
What should be reported?
A person making a report must have reasonable grounds to believe that a violation has occurred, is ongoing, or is about to occur, and that the information provided is true to the best of their knowledge. Knowingly submitting false reports is prohibited.
A violation generally refers to any act or omission that is unlawful or contrary to the purpose of applicable laws or regulations.
Under the Estonian Whistleblower Protection Act (implementing the EU Whistleblower Directive), a reporting person may be entitled to legal protection if the report concerns breaches relating to, among other things:
- Public procurement
- Financial services, products and markets, including the prevention of money laundering and terrorist financing
- Product safety and compliance
- Transport safety
- Environmental protection
- Radiation protection and nuclear safety
- Food and feed safety, animal health and animal welfare
- Public health
- Consumer protection
- Protection of privacy and personal data, and the security of network and information systems
- Violations affecting the financial interests of the European Union
- Violations relating to the EU internal market, including corporate tax rules and arrangements intended to obtain tax advantages that undermine the objectives of applicable corporate tax legislation
Reports may also concern other work-related misconduct involving significant breaches of legal requirements or internal policies and procedures.
Whistleblower Guarantees:
- Information: The whistleblower will receive an acknowledgment within seven days and a response about the measures taken within three months, extendable for another three. Individuals affected have the right to be informed of the accusations against them and to be heard.
- Confidentiality: The whistleblower can choose to identify themselves throughout the process, but the recipients of the report will never disclose the whistleblower’s identity or the facts and data of the procedure without their consent.
- Freedom from Retaliation: As long as the report is made in good faith, the whistleblower will be protected from retaliation.
- Support Measures: The whistleblower can seek confidential advice and support from the Human Resources department of Next Clinics and will have access to different support measures provided by competent bodies and authorities.
- External Channels: In addition to the internal reporting channel, the whistleblower can turn to other external reporting channels such as the National Commission of Markets and Competition (CNMC), the Executive Service of the Money Laundering Prevention Commission (SEPBLAC), the Independent Authority for the Protection of Whistleblowers, or the Spanish Data Protection Agency”.
Information on the Processing of Personal Data
Personal data is processed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation – GDPR) and the Estonian Personal Data Protection Act.