ESG Report

Our Environmental, Social and Governance policies

This policy has been established to enable employees and third parties to report (suspected) serious misconduct and/or irregularities. Here we explain the purpose of the policy, who it applies to, what kind of reports can be made, how a report is made, and what the safeguards are for both the reporter and the person under investigation.


Our policy aims to enable employees and third parties to report (suspected) serious misconduct and/or irregularities. In this way, Democo Group promotes a culture of openness and accountability. Democo Group expects all employees to behave in accordance with our core values and policies, and to comply with applicable laws and regulations. Our policy describes how employees and third parties can express their concerns in a confidential manner without fear of reprisals.


This policy applies to all employees who are bound by an employment or service contract and all possible third parties in relationship with Democo Group NV, including its current and future business units Construction, Techniques, and Real Estate Development. The companies currently under Democo Group are: Democo NV, Democo Group NV, CIRIL NV, Deholi NV, Vandenbriele NV, AEW NV, AEW Security BV, AEW Green BVBA, Debuild BV, Daeninck & Deweerdt BVBA and Demtec Services NV.

Misconduct or Irregularities

This policy distinguishes between social and business integrity. Social integrity concerns unwanted behavior, while business integrity concerns, among other things, confidential information, materials and goods, safety, environment, health, and contacts with customers and suppliers. Reports of social integrity violations are preferably made in accordance with the Policy on Transgressive Behavior at Work. Reports of (alleged) business integrity violations can be directed to the Integrity Officer.

Filing a Report

Reports of (alleged) business integrity violations can be directed to the Integrity Officer by email, letter, telephone, or through the online platform IntegrityLog. The online platform is accessible 24/7 and can be used anonymously. Anonymous reports must contain sufficient details to be processed. It is also possible to make a report to the Federal Ombudsman, for example, in situations where no response has been given to an internal report or where there is a clear threat or danger to the public interest. Evidence, documents, references, photos, or other relevant information will always be helpful to process a report more efficiently.

Integrity Officer:
Name: Sarah Van Heghe
Phone: +32 11 22 45 26 or +32 498 49 55 36
Address: Herkenrodesingel 4b, 3500 HASSELT


Federal Ombudsman:
Address: Leuvenseweg 48/6, 1000 BRUSSELS
Phone: 0800 99 961

Safeguards for the Reporter

Reports are treated confidentially, and information is shared on a need-to-know basis. All personal data is used only in accordance with Democo Group's GDPR policy. Democo Group encourages reporting of potential misconduct or irregularities without adverse consequences for the reporter. Reprisals are considered a serious violation of the policy.

Safeguards for the Subject of the Investigation

The person under investigation also has a right to protection and is notified within a reasonable time, unless this jeopardizes the investigation. Information is treated confidentially and shared with a limited number of people on a strict "need-to-know" basis. The investigated person has the right to respond to the allegations and can appeal against negative findings or decisions.

Abuse of Reporting Rights

Democo Group assumes that reports are made in good faith. No action will be taken against anyone who acted in good faith in the case of unfounded reports. However, intentionally false reports will be appropriately sanctioned and may result in dismissal for urgent reasons and liability for damages suffered.

Reporting (suspected) unethical or illegal behavior is of great importance for the integrity and reputation of Democo Group and contributes to a culture of openness and accountability. We encourage everyone to report any worries or concerns through the channels we make available. We are committed to treating reports seriously and carefully and respecting confidentiality. Together we ensure a safe and ethical working environment for our employees and third parties.

If you have any questions about this policy or would like to receive the full policy text, please contact the Integrity Officer: