Global Whistleblowing Procedure

Overview

1.1 This procedure outlines how employees and external stakeholders can raise concerns using the whistleblowing mechanism and how the Enhesa Group will handle any concerns raised.

1.2 If you have any questions related to the whistleblowing procedure, please reach out to the Whistleblowing Manager, Veronica Cacciatore.

Who can raise a concern?

1.3 Individuals who can raise a concern about a suspicion or breach of the Enhesa Group’s policies include the following:

• All prospective, current and former Enhesa Group employees, including full or part-time, permanent, fixed term or temporary employees
• Any third parties acting for the Enhesa Group, such as agents, consultants, freelancers, contractors, representatives, trainees and casual workers
• Any other stakeholders, such as suppliers, partners, customers or public officials, who through their interactions with the Enhesa Group, become aware of an issue of serious concern.

1.4 Any serious concerns in relation to the conduct of individuals employed by, or associated with, the Enhesa Group, or misconduct by the Group itself, can be raised through our whistleblowing mechanism.

1.5 Some of the types of misconduct you should report to the Enhesa Group include, but are not limited to:

• Criminal offences, including fraud, theft and embezzlement
• Corruption, bribery or blackmail
• Violation of competition laws and rules
• Human rights violations
• Bullying, harassment and discrimination
• Conflicts of interest
• Data protection and privacy violations
• Actions which endanger the health and safety of our employees, contract staff or the public
• Actions which endanger or damage the environment
• Any retaliatory actions against someone for speaking up.

How do you raise a concern and what should you include?

1.6 There are two ways you can speak up at the Enhesa Group.

• You can speak up by contacting the dedicated Whistleblowing Manager, Veronica Cacciatore.
  • By Phone: +32 (0)2 775 97 97 ext 810
  • By Email: vc@enhesa.com
  • In person or in writing: Avenue Louise 287 – 1050 Brussels (Belgium)
• If you feel it is not appropriate to raise a concern with the Dedicated Whistleblowing Manager, you can report your concern to the Whistleblowing Committee which is comprised of the Chief People Officer and the Chief Executive Officer.
  • Beatriz Preto – Chief People Officer
    By Email: beatriz.preto@enhesa.com
  • Peter Schramme – Chief Executive Officer
    By Email: peter.schramme@enhesa.com

1.7 All information about the concern being raised will be treated in strictest confidence.

1.8 You are not expected to have all the evidence nor are you encouraged to investigate the concern yourself. Your report can include any of the following information that you are able to provide:

• A description of the breach or potential breach of the Enhesa Group’s policies, or the illegal or fraudulent misconduct
• Any relevant documents, including emails or texts, related to the issue raised
• Full name of the individuals and organisation about whom a concern is raised
• Your full name and contact information (should you wish to provide it).

1.9 You must act in good faith when you raise a concern using the whistleblowing mechanism. This means you reasonably believe the information you report is true at the time of reporting, even if later the disclosure turns out to be false. You will not be penalised if your report is found to be incorrect; however, disciplinary sanctions may be applied to any individual who knowingly reports false information.

Protection against retaliation

1.10 Whistleblowers are protected against all actions of retaliation, such as suspension, lay-off, dismissal or equivalent measures; demotion or withholding of promotion; coercion, intimidation, harassment or ostracism; discrimination, disadvantageous or unfair treatment; and more.

1.11 Any form of retaliation or detriment will not be tolerated. Whistleblowers will suffer no detriment at the Enhesa Group and will not be subject to disciplinary measures if they have reported facts in good faith, even if those facts are found to be incorrect or are not followed by any disciplinary or legal actions.

1.12 If you feel you have or are experiencing detrimental or retaliatory behaviour as a result of making a whistleblowing report, you should report that to the Whistleblowing Manager or the Whistleblowing Committee using the above channels.

How will the Enhesa Group investigate the concern raised?

1.13 The review and investigation process of concerns raised will be conducted in a confidential, impartial and thorough manner. It will be carried out as promptly as possible without compromising the integrity or comprehensiveness of the process. All information collected, and actions taken will be documented and recorded.

1.14 The Enhesa Group will maintain the confidentiality of whistleblowers, persons under investigation, witnesses or other parties involved in the investigation. Information relating to the concern will only be shared on a strict need-to-know basis. If, as is the case in some instances, we are required by law to disclose the identity of the whistleblower, you will be informed.

1.15 We permit the anonymous reporting of misconduct, although this can make it more difficult for us to investigate concerns. Regardless of whether concerns are made anonymously, we assure you that your identity will be protected.

Receiving and registering speak up alerts

1.16 The Whistleblowing Manager will receive speak up alerts and follow up on the alert, making contact with the whistleblower and following up for further information. If necessary, they may decide to appoint another reporting manager who would take on these communication and follow-up responsibilities.

1.17 The whistleblower will be formally notified of the registration of their concern within seven days.

Investigating the concern

1.18 Following the registration of a concern, the reporting manager will determine whether the concern should be investigated.

1.19 Where the concern alleges inappropriate conduct by another individual, we may be obliged to inform the individual that a complaint has been filed against them, unless provisional measures are necessary so as, for instance, to prevent the destruction of evidence.

1.20 Should circumstances require, the Enhesa Group may engage external auditors, counsel or other experts to assist in the investigation and the analysis of the results. The whistleblower will be given the opportunity to speak to investigators to explain their concerns.

1.21 The investigation or review will be conducted, and an investigation report will be prepared, concluding whether the misconduct is substantiated. The report will be passed to the Whistleblowing Committee for review and in due course, endorsement. The Whistleblowing Committee will decide what action, including any disciplinary action, to take and preventative measures necessary to avoid reoccurrence.

1.22 If enquiries indicate that the concern has no basis, or it is not a matter to be pursued under this policy, it may be dismissed, and the decision will be documented by the reporting manager.

1.23 Personal data collected as part of the whistleblowing mechanism and throughout the investigation will be retained by the Enhesa Group only for as long as there is a need for it in line with personal data protection rights. When there is no longer a need for retaining the registered information, the personal data will be deleted.

Follow up

1.24 The reporting manager will follow up with the whistleblower on action the Enhesa Group has taken or will take with regard to the reported concern no later than three months after the concern is raised.

1.25 We may not be able to provide full details of the outcome of a case (or related actions taken) for reasons of confidentiality, privacy and the legal rights of all concerned.

Application of the European Whistleblowing Directive in Belgium

In Line with the European Whistleblowing directive, Belgium has put in place additional services for the citizens that prefer to make their report through an external channel. The Federal Ombudsman can receive and investigate reports of breaches of professional integrity in the following areas:

• public procurement;
• services;
• financial products and markets and 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 welfare;
• public health;
• consumer protection;
• protection of privacy and personal data;
• security of networks and information systems;
• combating tax and social fraud.

Whistleblowers can contact the Federal Ombudsman through the dedicated website.

https://www.federaalombudsman.be/en/whistleblowers

Also, whistleblowers can find additional information and support at the Federal Institute of Human Rights:

https://institutfederaldroitshumains.be/