1. Purpose - Why?

Our corporate values and behavioural guidelines are elaborated in the Ctrl-F Code of Conduct & Ethics With our Code of Conduct & Ethics, we aim to set out the corporate values and principles in our professional and personal behaviour and commit ourselves to fulfilling our mission in an ethical manner.
This procedure provides additional regulation of our vision and principles in the context of whistleblowing, as described in the Code of Conduct & Ethics. It provides a framework for internal reporting and for following up suspected misconduct. We believe that everyone can and should raise awareness if they believe in good faith that unethical practices or misconduct is going on.
This regulation was also adopted to implement Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law as well as the Belgian legislation transposing the Directive into national law. The overall aim of the European directive and the Belgian law is to protect whistleblowers from retaliation in any form and to require public and private organisations to establish formal procedures for internal reporting and follow-up of reports.
We stress that everyone has a responsibility to contribute to and maintain a culture of transparency and openness, free from retaliation. More specifically the management of Ctrl-F bears an important responsibility to act in accordance with our core values and policies. They should not only lead by example, but also support their team members in their efforts to uphold these principles.

2. Scope - Who?

In accordance with the European directive and Belgian legislation, Ctrl-F's Whistleblower Policy applies not only to current and future employees, but also to former employees, self-employed persons, shareholders and persons belonging to the administrative, management or supervisory body, volunteers and paid or unpaid trainees, job applicants, all persons working under the supervision and direction of contractors, subcontractors and suppliers.
Consequently, the internal reporting channels described in these regulations will be opened to all the aforementioned parties, all of whom will be protected by Ctrl-F from retaliation.

3. Misconduct - what?

This Whistleblower Policy applies to all suspected or actual (attempted) unlawful, unethical or non-legitimate behaviour relating to Ctrl-F (hereinafter the "reportable breaches").
For the purpose of this scheme, a distinction is made between the following types of reportable infringements:

1) Infringements falling within the scope of the European Directive and Belgian law, namely infringements relating to:
- Public procurement;
- Financial services, products and markets and prevention of money laundering and terrorist financing;
- Product safety and compliance;
- Transport safety;
- Environmental protection;
- Infringements affecting the Union's financial interests and/or related to the internal market;
- Food and feed safety, animal health and welfare;
- Public health;
- Consumer protection;
- Protection of privacy and personal data, and security of network and information systems;
- Social fraud;
- Tax fraud;
- Radiation protection and nuclear safety;

Ctrl-F's Whistleblowing Policy applies not only to breaches in the workplace, in public and private places, but extends to infringements relating to all work-related activities such as (non-exhaustive):
- During conferences, seminars or training courses
- During work-related trips
- During after-work events
- Through work-related communication
- In accommodation provided by the employer, for example when providing residential facilities to people at work

Ctrl-F emphasises and undertakes to protect from retaliation all persons reporting suspected or actual (attempted) breaches in good faith.

4. Blow the whistle! - How to.

Breaches of Union law must be detected, addressed and remedied at an early stage. Providing channels for reporting infringements or misconduct ("whistleblowing") is essential.

This Whistleblowing Policy is intended to provide internal channels for reporting observations or findings of (suspected) breaches related to Ctrl-F without having to follow the hierarchical route or the usual channel. It does not replace but complements existing procedures for handling (individual) complaints or irregularities. Whistleblowing channels are established to report (attempted) illegal, unethical or non-legitimate behaviour when it cannot be reported through the usual channels, such as the direct supervisor, the HR manager or another regular designated person.

We encourage all employees of Ctrl-F , former employees, self-employed persons, shareholders, persons belonging to the administrative, management or supervisory body, volunteers and trainees, job applicants, all persons working under the supervision and direction of contractors, subcontractors and suppliers to report any kind of suspected or actual violations or misconduct through the dedicated internal channels implemented by Ctrl-F. We take all reports received seriously and are committed to investigating every report.

You can report in several ways:
If possible, discuss the issue with your reporting manager in person, by phone or email

Melissa Goossens
HR Legal Expert
+ 32 470 99 25 18

Joke Vancoppernolle
Company lawyer
+ 32 496 71 35 52

If you feel unable to do so, you can report the misconduct via our reporting tool (SPOT):

Spot allows you to raise actual or suspected misconduct in an accessible and, if desired, anonymous way. The customised workflow within Spot guides whistleblowers through the entire process. Each issue is handled and followed up according to existing escalation procedures. Open the tool via talktospot.com/hohr or via the QR code.

While Ctrl-F hopes that reporting a concern through the internal reporting channels will provide sufficient relief and is therefore preferable, there may be circumstances where it is more appropriate to report a concern directly to an external body. If applicable, you can report your concern directly to the Federal Ombudsman .

5. Treatment and research

For each report, you will receive an acknowledgement of receipt within seven calendar days. The reporting manager will also inform you whether the report is assessed as potential misconduct, or whether it is a matter to be dealt with through normal reporting procedures. If deemed necessary, the reporting manager, together with whistleblower committee (composed of: company lawyer, HR Legal Expert, Audit manager and the operations manager), will investigate the content of the report.

During the investigation, the reporting manager may also contact you (through SPOT or, if possible, directly) for further clarification. As required by the European Directive, Ctrl-F must respect the right of the persons named in the report to be heard and the right to access their file, taking into account the anonymity and confidentiality of the report and the reporter and without compromising the investigation.

Within three months of the acknowledgement of receipt, the reporting manager will, to the extent possible and subject to any applicable confidentiality requirements or privacy issues relating to anyone who is the subject of the report, report to the reporter on the status of the investigation and any mitigating measures taken.

All reports are kept confidential and information is shared only on a 'need to know' basis. Records of each report will not be kept longer than necessary and appropriate to meet the requirements of the Directive.

All personal data processed by Ctrl-F under this Whistleblower Scheme shall be carried out in accordance with applicable law and shall be used solely to fulfil the purposes of this Scheme.

6. Non-retaliation

The identity of the reporter and any other information from which the identity of the reporter can be directly or indirectly deduced shall be kept confidential as far as possible. Such information may only be disclosed where this is a necessary and proportionate obligation imposed by Union or national law in the context of investigations by national authorities or judicial proceedings. If information is disclosed, the reporter shall be informed before his identity is disclosed, unless such information would jeopardise the relevant investigation or judicial proceedings.

The reporter who acts in good faith and on reasonable grounds ("well-founded reasons"/"motifs raisonnables") is protected from retaliation by this Whistleblowing Policy. There are no repercussions for reporting a (potential) breach in good faith and on reasonable grounds, even if the report is subsequently found to be unfounded. This means that the reporter may not be disadvantaged in any way as a result of his or her report.

If the reporter proves that he or she has been punished, treated unfairly or otherwise disadvantaged as a result of his or her report, it will be assumed that the damage was inflicted in retaliation for the report, unless the person who took the negative action can prove that that action was based on justifiable reasons and had no connection whatsoever with the reporter's reporting act. If the investigation shows that a report was false or made in bad faith, this may be grounds for taking appropriate and reasonable action against the reporter. Any person who violates the provisions of these regulations may be subject to disciplinary action, including dismissal.