Regulations of the VCK Reporting Channel
Introduction
VCK attaches great importance to integrity, safety, respect and compliance with laws and regulations. For that reason, VCK provides a confidential reporting channel through which employees, clients, suppliers and other stakeholders can report possible misconduct.
This reporting channel offers the possibility to report behaviour that is contrary to laws and regulations, internal policy rules, the VCK code of conduct or generally accepted standards of integrity and good business conduct.
Reports are handled by an independent officer within the Ership Group, who is responsible for the careful, objective and confidential handling of reports.
1. Scope
These regulations apply to anyone who wishes to submit a report about possible misconduct within VCK or Maja.
Reports may relate to current, former or future working or business relationships.
2. What can be reported?
The reporting channel can be used to report, among others, the following matters:
- breaches of laws and regulations;
- fraud, theft or embezzlement;
- corruption or conflicts of interest;
- discrimination, harassment, bullying or other inappropriate behaviour;
- breaches of internal rules, procedures or codes of conduct;
- safety or environmental risks;
- other serious misconduct that may damage the integrity of the organisation.
3. Submitting a report
Reports can be submitted via the designated reporting form.
A report should, as far as possible, contain a clear description of the facts and circumstances, supplemented by any relevant documents or other supporting evidence.
It is permitted to submit a report anonymously.
4. Confidentiality
All reports are treated confidentially.
The identity of the reporter is disclosed only where necessary for the handling of the report or where required by law. The reporter is informed in advance, unless this is not legally permitted.
5. Protection of the reporter
Any person who makes a report in good faith is protected against detrimental treatment as a result of that report.
Detrimental treatment includes, among others:
- dismissal or suspension;
- intimidation or threats;
- discrimination;
- adverse changes to terms of employment;
- other forms of retaliation.
VCK does not accept any form of detrimental treatment of persons who make a report in good faith.
6. Rights of those concerned
Persons to whom a report relates are entitled to careful and fair treatment.
They are entitled, among others, to:
- the presumption of innocence;
- the right to be heard;
- protection of their privacy;
- the correct processing of personal data.
7. Handling of reports
Upon receipt of a report, the reporter receives, where possible, an acknowledgement of receipt within seven days.
The report is assessed by the independent officer responsible for the reporting channel. Where necessary, a further investigation is initiated.
The reporter receives information on the progress or outcome of the handling within three months of receipt of the report, unless legal restrictions prevent this.
8. Personal data
VCK processes personal data provided via the reporting channel solely for the purpose of receiving, assessing, investigating and handling reports.
Reports are treated confidentially. Personal data is accessible only to persons involved in the handling of the report and only to the extent necessary for their duties.
The identity of the reporter is not disclosed without their consent, unless VCK is legally obliged to do so.
Personal data is not kept for longer than is necessary for the handling of the report and for meeting legal obligations.
The processing of personal data within the reporting channel is also subject to the VCK privacy policy. That policy provides additional information about the processing of personal data and the rights of those concerned. The privacy policy is available at www.vck.nl.
9. Reports made in bad faith
If it appears that deliberately false or misleading information has been provided, VCK may take appropriate measures.
The mere fact that a report proves to be unfounded following an investigation does not mean that the report was made in bad faith.
10. External reporting options
In addition to this internal reporting channel, a reporter may, where there is reason to do so, turn to a competent authority or another body as referred to in the Whistleblower Protection Act.
11. Final provisions
VCK reserves the right to amend these regulations where legislation, case law or organisational circumstances give cause to do so.
These regulations take effect on the date of publication on the VCK website.
