Whistleblower report

Purpose
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 responsibility. Democo Group expects all employees to conduct themselves in conformity with our core values and policies, and to comply with applicable laws and regulations. Our policy describes how employees and third parties can confidentially raise concerns without fear of reprisal.

Scope of application
This policy shall apply to all employees working under an employment or service contract, as well as to all possible third parties who have a relationship with Democo Group NV, including with its current and future Construction, Techniques and Project Development business units. The Democo Group currently comprises the following companies: Democo NV, Democo Group NV, CIRIL NV, Deholi NV, Vandenbriele NV, AEW NV, AEW Security BV and Demtec Services NV.

Misconduct or irregularities
This policy makes a distinction between social and business integrity. Social integrity relates to undesirable behaviour, while business integrity is concerned with confidential information, equipment and goods, safety, environment, health and contacts with customers and suppliers, among others. Reports of social integrity violations shall preferably be made in accordance with the Policy on Transgressive Behaviour in the Workplace. Reports of (alleged) business integrity violations may be addressed to the Integrity Officer.

Submitting reports
Reports of (alleged) business integrity violations may be addressed to the Integrity Officer by email, letter or telephone, or via the online platform IntegrityLog. The online platform is accessible 24/7 and can be used anonymously. However, anonymous reports must contain sufficient details in order to be taken up for consideration. A report may also be made to the Federal Ombudsman, for example in case there has been no response to an internal report or in case there is an imminent or clear danger to the public interest. Evidence, documents, references, photographs or other relevant information will help each entity to handle a report more efficiently.

Integrity Officer:
Name: Sarah Van Heghe
Email: integrityofficer@democogroup.com
Telephone: +32 11 22 45 26 or +32 498 49 55 36
Address: Herkenrodesingel 4b, 3500 HASSELT

IntegrityLog:
Fill in this form

Federal Ombudsman:
Email: contact@federaalombudsman.be
Address: Leuvenseweg 48/6, 1000 BRUSSELS
Website: https://www.federaalombudsman.be/en
Telephone: 0800 99 961 

Safeguards for the reporter
Reports shall be treated confidentially and information solely shared on a need-to-know basis. All personal data shall only be used in accordance with Democo Group’s GDPR policy. Democo Group encourages the reporting of possible misconduct or irregularities without any adverse consequences for the reporter. Reprisals shall be considered to be a serious violation of the policy.

Safeguards for the subject of the investigation
The person under investigation is also entitled to protection and will be informed within a reasonable time, unless this would compromise the investigation. Information shall be kept confidential and shared with a limited number of people on a strict need-to-know basis. The person under investigation shall have the right to respond to allegations and may appeal against adverse findings or decisions.

Reporting (suspected) unethical or wrongful behaviour is extremely important for the integrity and reputation of Democo Group and contributes to a culture of openness and accountability. We encourage everyone to report any concerns or worries through the channels that we have provided. We are committed to treating reports seriously and carefully and to respecting confidentiality. Together, we ensure a safe and ethical working environment for all our employees and third parties.

If you have any questions about this policy, please contact the Integrity Officer.