Whistleblowing Policy

OC&C is committed to conducting business with honesty and integrity and we expect all employees to maintain the same high standards.  However, all organisations face the risk of unknowingly harbouring malpractice or wrongdoing, and therefore, we expect you to understand the importance of preventing and eliminating wrongdoing at work and be watchful for illegal or unethical conduct.

Any suspected wrongdoing should be reported without delay. We will take appropriate action to identify issues and attempt to remedy them.

This policy outlines what qualifies as a whistleblowing report, the process for submitting a report, the individuals authorised to make a report, and the protections in place to safeguard them.

This policy is implemented in accordance with the EU Directive concerning the protection of persons who report violations of EU laws.

What can be reported

Whistleblowing is the disclosure of information which may relate to health and safety issues, fraud or other illegal or unethical conduct in the workplace. A disclosure is one made in the public interest by an employee or worker who has a reasonable belief that;

  • a criminal offence,
  • a miscarriage of justice,
  • an act creating risk to health and safety,
  • an act causing serious damage to the environment,
  • a breach of any other legal obligation, or
  • concealment of any of the above

is being, has been, or is likely to be, committed. It is not necessary for you to have proof; reasonable belief is sufficient.

If you have a complaint regarding your terms and conditions of employment, working conditions, or any other internal matter outside of those listed above, you should raise with your manager or a member of HR.  This type of complaint is not deemed as whistleblowing.

Who can report

Individuals who have reasonable belief that misconduct has occurred in the context of their work environment. Specifically:

  • Employees, Partners, temporary workers and interns
  • Advisors, independent contractors
  • Suppliers
  • Prospective and terminated employees

 

How to report

We encourage you to raise any concerns with your manager and a member of the HR team in the first instance. We will then arrange a meeting with you as soon as possible to discuss your concern.  You may be accompanied by a colleague or union representative, who must respect the confidentiality of your disclosure and any subsequent investigation.

Where you prefer not to raise it with your manager, office lead or a member of HR, you have the following options to submit a report:

1) A member of the Risk Committee (available to all permitted individuals)

2) Reporting platform – Vault (available to OC&C employees only)

The internal persons responsible for handling reports include members of the Risk and Audit Committee (“RAC”).  The RAC is composed of authorised and Directors and Partners responsible for Information Security, Risk Management, Data Privacy and Code of Conduct. Reports will be acknowledged, and further feedback will be provided to the whistleblower within 3 months.

If you feel that an issue cannot be dealt with through firm channels or isn’t being dealt with by those channels in an appropriate manner, we have also established a fully independent external Ombudsman:

All communication with the ombudsman is strictly confidential. The ombudsman has a mandate to investigate the issue raised by a Whistleblower.

Reports, which can also be made anonymously, should be as detailed as possible to ensure a thorough investigation, and include:

  • your full name and office, as well as an email address to which subsequent updates can be communicated (unless remaining anonymous)
  • the circumstances of time and place in which the reported event occurred, a description of the facts, and how the facts became known to you
  • the name, job title and function of the person(s) responsible for the misconduct
  • details of any other witnesses who may be able to substantiate the claims within the report
  • any other information, documentation and details relevant to establish the facts

We do not encourage individuals to make disclosures anonymously, although we will make every effort to investigate anonymous disclosures. You should be aware that proper investigation may be more difficult or impossible if we cannot obtain further information from you. It is also more difficult to establish whether any allegations are credible.

[Under specific conditions, the law permits reports to an authorised external body such as the Dutch Authority for the Financial Markets.

We strongly encourage you to seek advice from our internal contacts (Legal Counsel, HR or the Risk and Audit Committee) before reporting a concern externally.

We are obliged to note that false and deliberate disclosures made in bad faith, will be treated as misconduct and dealt with under the disciplinary procedure.

Protections

You can raise any matters of legitimate concern without fear, in the knowledge that any disclosure will be taken seriously and that the matters will be investigated appropriately.

You are protected by law and have the right not to be dismissed, subjected to any other detriment, or victimised, because you have reported wrongdoing (or genuinely believed wrongdoing) in accordance with this policy.  Your identity will also be protected, unless you give your consent to disclose that information, or in the exceptional circumstances where the disclosure is required by law.