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Losberger De Boer's Whistleblower policy

Whistleblower Policy

Purpose

Losberger De Boer is committed to conducting all business activities fairly, transparently, honestly and in full compliance with all legal and regulatory standards. For this purpose Losberger De Boer has implemented a Code Of Conduct applicable both towards its customers and towards Losberger De  Boer`s personell.

To support the implementation of the Code of Conduct and to fulfill the commitments made therein it is necessary to provide a clear and robust whistleblowing policy.

The purpose of this policy is to ensure compliance with the principles outlined in Losberger De  Boer`s Code of Conduct. All reports or concerns regarding improper, unethical or illegal behaviour concerning any aspect of Losberger De Boer’s property, personnel, suppliers, customers or any additional third parties involved in Losberger De Boer`s activities, must be addressed effectively, securely, appropriately and in full accordance with the applicable (local) laws.

Losberger De Boer encourages all personnel and partners to report these concerns and will provide guidance and channels to do so.

Scope

This policy applies to all Losberger De Boer entities and personnel (including directors, shareholders, executives, employees, contractors, consultants and interns) regardless of the team or office they work in. This policy also relates to any actions or concerns related to Losberger De Boer suppliers, customers, or any other third party with whom Losberger De Boer has dealings.

Reportable conduct

At Losberger De Boer, we encourage all personnel to report any behaviour or situation they find concerning. This can be categorised in to ways:

First Category: Threats to company reputation or financial health

This category encompasses behaviours that could potentially compromise Losberger De Boer’s reputation or financial stability. The following list provides guidelines on what should be reported. It is by no means exhaustive, and personnel are encouraged to use their best judgment if they witness concerning behaviour that falls outside of the listed items. 

  • Fraud
  • Theft
  • Embezzlement
  • Corruption
  • Bribery
  • Financial malpractice
  • Tax evasion
  • Blackmail
  • A miscarriage of justice
  • Failure to comply with regulatory requirements
  • The provision of false information to public officers
  • Conduct that threatens Losberger De Boer’s reputation or financial well-being
  • Failure to comply with legal or professional obligations
  • Unauthorised disclosure of confidential information
  • Actions that would endanger the health or safety of Losberger De Boer personnel or the public
  • Actions that cause damage to the environment

 

Second Category: Concerns regarding the well-being and effectiveness of personnel

This category includes any actions or behaviours that could potentially impact the effectiveness and productivity of Losberger De Boer personnel. This is a broader category of behaviours. Should you have concerns regarding the well-being of a colleague or if you have a suggestion for how Losberger De Boer could improve the workplace or the environment, we encourage you to raise the issue.

Losberger De Boer cannot guarantee that each issue mentioned in this category will be addressed, in contrast to the issues mentioned in the first category above. Nevertheless, Losberger De Boer is committed to creating workplaces that are open, transparent and pleasant.

The issues to be addressed could include but are not limited to:

  • Concerns about a colleague's emotional, mental, or physical health.
  • Suggestions for how to improve the workplace.
  • Concerns about discrimination, exclusion or other forms of unfair treatment.
  • Concerns about a colleague's or a supervisor´s behavior: This could include behaviours such as mobbing, bossing, sexual harassment, threatening behaviour, or behaviour that makes other personnel feel uncomfortable.

How to make a disclosure

Please consult with your supervisor

The preferred method for raising concerns is to consult with your direct supervisor. Please send an email requesting for a meeting at your earliest convenience and use this as an opportunity to raise the issue there.

Should you wish to remain anonymous or be concerned that your supervisor is somehow involved in the concerning activity or their response is insufficient you may raise the issue with the member of Losberger De Boer that you believe should be aware of it.

Persons who are not Losberger De Boer`s members are requested to use directly the Face App Whistleblowing System.

Use the anonymous whistleblowing system

Should you wish to remain anonymous, please use the FaceUp Whistleblowing System (link here). Simply enter Losberger De Boer code: 1234abcd. Please select the category of concern and provide any additional information that you believe are necessary to facilitate a comprehensive understanding of the issue.

Upon submission of the report you will receive a case code. You are welcome to log back into Faceup at any time to track the progress of your report. This case code is also useful for another reason. Should the person who has received your report require more information he can contact you to ask additional questions while maintaining the confidentiality of your identity.

Report to relevant authorities (exceptional cases)

Finally, Losberger De Boer acknowledges that there may be extreme circumstances where it is necessary to consult an external third party such as a regulator or the police. Losberger De Boer strongly encourages you to seek guidance and advice before going to a third party. 

Investigation

Upon receipt of a report, it will be allocated to the relevant Losberger De Boer`s department for assessment. Should the report be considered credible, an investigation will be launched. The individual who has provided the information whistleblower may be contacted via the Faceup app to request further details. Should the report be found to have been deliberately false, the individual who has submitted it may be subject to disciplinary action.

Company Response

In the event of illegal criminal activity being discovered Losberger De Boer will refer the case to the relevant authorities and provide all of the evidence gathered. In the event of other illegal or legal but concerning activity, Losberger De Boer will respond on a case-by-case basis. This response may take form of lending assistance and support to personnel who may be struggling, or, should a person be found to be behaving in a way that violates the terms of their contract, Losberger De Boer`s Code of Conduct or is contributing to a hostile work environment, their immediate dismissal.  

Protection for whistleblowers

At Losberger De Boer, we are committed to safeguarding the identity of individualy who come forward with concerns. We will take all necessary measures to protect their identity and prevent any form of retaliation.

Any form of harassment, discrimination or retaliation against the whistleblower will not be tolerated. Any form of retaliation will be considered as grounds for disciplinary action or dismissal.