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techniek detachering bureau

MODEL WHISTLEBLOWER POLICY FOR TRINAMICS BEHEER BV, TRINAMICS NEDERLAND BV, AND TRINAMICS ENGINEERING BV

Trinamics considers it important that employees can report suspected wrongdoing in a safe manner, without fear of negative consequences.

Based on the Whistleblower Protection Act, Trinamics has established the following reporting procedure, which is provided to individuals working at Trinamics. This procedure enables employees to report concerns at an early stage and contributes to Trinamics' effective response. Trinamics aims to foster an open culture where integrity and holding each other accountable for behavior are encouraged and valued.

ARTICLE 1 – GENERAL This reporting procedure is intended for reporting suspicions of wrongdoing, where the suspicion is based on reasonable grounds and where there is a societal interest at stake. This reporting procedure is not intended for (individual) labor disputes, reporting personal complaints about work-related matters and/or compensation, criticizing Trinamics' policy choices, and/or for personal gain.

 

ARTICLE 2 – DEFINITIONS In this reporting procedure:

  1. Employee: the person who performs or has performed work under an employment contract, or the person who performs work other than under an employment contract.
  2. Employer: Trinamics, which employs or has employed individuals under an employment contract, or the entity that engages or has engaged individuals to perform work other than under an employment contract.
  3. Suspected wrongdoing: the suspicion of an employee that there is wrongdoing, provided that: a. the suspicion is based on reasonable grounds arising from the knowledge gained by the employee through their work for the employer or through their work for another company; and b. there is a societal interest at stake in: • the violation of a legal provision; • the violation or risk of violation of Union law; • a risk to public health; • a risk to the safety of individuals; • a risk to the environment; • the violation of the employer's internal rules; • a risk to the proper functioning of the public service or business as a result of improper action or omission.
  4. Ethical committee: the individual(s) designated to serve as such for the employer's enterprise and who can be consulted in confidence by an employee regarding a suspicion of wrongdoing.
  5. Highest management: the body or person responsible for the daily management of the employer's enterprise.
  6. Ethical committee: the body within the employer's enterprise responsible for supervising the highest management.
  7. External authority: the authority that, in the opinion of the reporting party, is most suitable for making an external report of wrongdoing.

 

ARTICLE 3 – INTERNAL REPORTING, INFORMATION, ADVICE, AND SUPPORT

  1. An employee can consult the ethical committee in confidence about a suspicion of wrongdoing and request information, advice, and support. The employee with a suspicion of wrongdoing can report it to the ethical committee within Trinamics. If the employee reasonably suspects that the immediate or highest management, or others, are involved in the suspected wrongdoing, the report can also be made to the ethical committee.
  2. The report can also be made through the ethical committee. The ethical committee forwards the report.

The employee can report in the following ways:

  • In writing: Trinamics Beheer Confidential Attn: Ethical committee Fellenoordstraat 86 4811 TJ Breda

  • By phone: Ethical committee Rutger Bartelink (mobile): +31628596722 Kadir Catlak (mobile): +31651439215 Margo van Balen (confidential advisor) (mobile): +31655326165

  • In person: By request, within a reasonable period, through a conversation at a designated location.

 

ARTICLE 4 – PROCEDURE AFTER INTERNAL REPORTING

  1. The recipient of the report ensures that it is documented in writing in a register, including a description of the report and the date it was received.
  2. The employee receives a confirmation of receipt within seven days of the report being received.
  3. The Ethical committee investigates whether the report concerns a suspicion of wrongdoing.
  4. The employee receives information on the assessment and (if applicable) the follow-up of the report within a reasonable period, but no later than three months after the confirmation of receipt.
  5. If the Ethical committee decides to inform an external authority about the internal report, the reporting party receives a copy of this, unless there are serious objections and/or it would harm the interest of the investigation or enforcement.
  6. If the Ethical committee decides to conduct an investigation, it will be carried out by independent and impartial investigators and not by individuals who may be or have been involved in the suspected wrongdoing. The reporting party is promptly informed of this in writing.

 

ARTICLE 5 – CONDUCTING THE INVESTIGATION

  1. The investigators provide the reporting party and other involved parties with the opportunity to be heard and prepare a draft investigation report. The reporting party is given the opportunity to provide comments unless there are serious objections. The aim is to finalize the investigation report within six months of the report being made.
  2. The Ethical committee informs the reporting party in writing of the substantive position regarding the report. It also indicates any (follow-up) steps resulting from the report.

 

ARTICLE 6 – EXTERNAL REPORTING

  1. The employee can make an external report of a suspicion of wrongdoing directly.
  2. The employee must make the external report to the House for Whistleblowers or to an authority designated by law. For more information, see: External Reporting Channels | What has changed? | Whistleblower Protection Act.
  3. The employee can also make an external report of a suspicion of wrongdoing after making an internal report.
  4. Internal reporting is preferred and will be encouraged as much as possible.

 

ARTICLE 7 – PROTECTION AGAINST DETRIMENT

  1. If the reporting party, acting in good faith and in accordance with the provisions of this reporting procedure, reports a suspicion of wrongdoing, Trinamics will not disadvantage the reporting party in any way.
  2. Trinamics ensures that colleagues of the reporting party refrain from any form of detriment related to the good faith and proper reporting of a suspicion of wrongdoing, which would impede the professional or personal functioning of the reporting party.
  3. If the reporting party believes they have been subject to detriment, they may discuss it immediately with the confidential advisor. The confidential advisor informs the direct supervisor and the Ethical committee.
  4. Trinamics will also not disadvantage other involved parties in any way, including, but not limited to, the Ethical committee and/or the investigators.

 

ARTICLE 8 – CONFIDENTIALITY

  1. Trinamics ensures that information about the report is stored in such a way that it is physically and digitally accessible only to those involved in handling the report. Trinamics treats the information it receives confidentially and processes it – to the extent permitted – in accordance with the provisions of the General Data Protection Regulation and other relevant legislation.
  2. Trinamics ensures that those involved in handling a report do not disclose the identity of the reporting party without explicit written consent from the reporting party and treat the information about the report confidentially.