Whistleblower Procedure
Whistleblowing Policy
The Whistleblowing Policy of Snel Logistic provides employees, suppliers and customers with a means of reporting misconduct or actions that constitute a breach of applicable legislation and/or the Code of Conduct.
The Whistleblowing Policy has been approved by the Management Team of Snel Logistic and applies throughout the entire Group. The Policy takes into account the applicable legislation in each country in which the Group operates.
Matters reported by a whistleblower will be handled confidentially and sensitive information will be stored securely.
What can you report?
You may report breaches of our Code of Conduct or violations of the law, including cases relating to bribery and corruption, competition law, fraud, financial crime, harassment and discrimination, international trade restrictions, personal data protection, the rights and protection of individuals, serious environmental damage, or conflicts of interest.
Whistleblowing Guide
This guide explains how you can confidentially report serious and sensitive concerns relating to illegal or unethical conduct and how such reports will be handled.
1. Purpose
1.1. When a person breaches a law or an internal policy, they place the companies within the Snel Logistic Group, and potentially other colleagues, at risk.
The sooner such misconduct is brought to an end, the better it is for everyone involved. Therefore, Snel Logistic has implemented a Whistleblowing Procedure (the “Whistleblowing Procedure”), which applies to all Snel Logistic locations and has the following objectives:
(a) to ensure that employees and managers of the Snel Logistic Group, as well as other stakeholders such as suppliers, distributors and customers, have the opportunity—alongside the existing internal communication channels—to report serious and sensitive concerns relating to breaches of, for example, the Snel Logistic Group Code of Conduct or any applicable legislation; and
(b) to serve as an early warning system by ensuring that the management of the Snel Logistic Group is informed of such concerns at the earliest possible stage so that it can
(i) assess and investigate the concern
(ii) where necessary, take appropriate and adequate measures to mitigate the consequences of a potential breach, threat or other serious risk.
1.2. For the avoidance of doubt, reporting under this Whistleblowing Policy is voluntary. This Whistleblowing Policy does not replace the existing internal communication channels.
2. Types of Concerns
2.1. The types of matters that may be reported under this Whistleblowing Policy are serious and sensitive issues that may adversely affect the activities and performance of the Snel Logistic Group.
Such matters include, but are not limited to:
(a) accounting or auditing matters, or irregularities of a financial, legal and/or ethical nature, including:
(i) fraud (e.g. financial fraud, document fraud or embezzlement);
(ii) serious deficiencies or intentional errors (for example in financial reports or statements, or in internal accounting controls);
(iii) violations of competition (antitrust) law (e.g. price-fixing);
(iv) child labour, forced labour or human trafficking;
(v) bribery or corruption; and
(b) other irregularities of a general and/or operational nature, such as serious threats to the vital interests of the Snel Logistic Group or to the life or health of individuals, environmental offences, serious shortcomings in workplace safety, or serious forms of discrimination or harassment.
3. Who Can Make a Report?
3.1. All employees of the Snel Logistic Group, as well as external stakeholders (such as contractors, suppliers, customers or other third parties), may report concerns under this Whistleblowing Policy.
4. What Can Be Reported and About Whom?
4.1. Reports may be made concerning serious matters and/or related acts or omissions within the Snel Logistic Group.
5. How to Make a Report
5.1. If you wish to make a report, you may send a letter, in the language of your choice, to the following address:
Snel Logistic
E3 laan 62 – 66
9800 Deinze
Belgium
For the attention of: Confidential Adviser
Anonymity
However, it cannot be guaranteed that the Whistleblowing Officer will not be able to identify the whistleblower based on the circumstances of the case.
The Whistleblowing Officer will be informed upon receipt of the reported concern.
5.2. If the concern relates to the Whistleblowing Officer, he or she shall be excluded from handling the case and from the decision-making process. If the concern involves a member of the Group Management, the Board of Directors shall be informed as soon as possible.
6. What If Someone Makes a Report About Me?
6.1. If a concern raised in a report relates to you, you will be informed accordingly by the Whistleblowing Officer.
7. Investigation of Concerns
7.1. Upon receipt of a concern falling within the scope of this Whistleblowing Policy, the Whistleblowing Officer will assess the concern and—provided that the information has been submitted in good faith—initiate an investigation. For the purpose of carrying out the investigation, the Whistleblowing Officer will inform and consult the members of the Investigation Committee, consisting of the CEO, the CFO and the HR Manager.
7.2. The Investigation Committee shall then, in cooperation with the relevant subject matter expert, agree upon and conduct the investigation into the concern and ensure that the necessary corrective and preventive measures are taken by management. A written report containing the findings of the investigation and the measures taken shall be submitted to management.
8. Right to Respond and Protection Against Retaliation
8.1. As soon as reasonably practicable, the person or persons whose conduct has been reported shall be informed of the substance of the concern raised in order to give them the opportunity to present their views. However, such notification may be postponed where there is a significant risk that informing the person concerned could compromise the investigation or adversely affect any subsequent actions or measures to be taken.
8.2. Where possible and appropriate, the Whistleblowing Officer shall inform the whistleblower whether the report has been closed or whether it will be subject to further investigation.
8.3. A person who reports a concern under this Whistleblowing Policy shall be protected against any form of retaliation or discriminatory or disciplinary action arising from the report, including dismissal, demotion, suspension, threats or any other form of intimidation, even where the whistleblower’s identity must be disclosed due to legal requirements, internal obligations or in the course of an investigation. Any such retaliatory measures against a whistleblower shall be regarded as a serious breach of this Whistleblowing Policy. This protection shall not apply where the whistleblower knowingly makes a false allegation or an allegation which, in light of all the circumstances, is manifestly unreasonable.
9. Implementation of the Whistleblowing Policy
9.1. The Whistleblowing Policy has been adopted by the Board of Directors of Snel Logistic and applies throughout the entire Snel Logistic Group. It shall be implemented at all locations, taking into account the requirements of the applicable legislation in each country in which it operates, including with regard to:
(a) the types of matters that may be reported under the Whistleblowing Policy;
(b) the persons about whom reports may be made under the Whistleblowing Policy;
(c) the persons who are entitled to make a report under the Whistleblowing Policy;
(d) the possibility of making reports anonymously or by name; and
(e) any other adaptations required by local legislation.
9.2. Management is responsible for implementing the Whistleblowing Policy and for ensuring that all employees are informed of its contents.
9.3. The Snel Logistic Group shall ensure compliance with applicable local data protection legislation and the Snel Logistic Privacy Policy, in particular with regard to:
(a) the application of the principles of data quality and proportionality;
(b) the provision of clear and comprehensive information concerning this procedure and policy;
(c) the rights of the persons concerned by a report;
(d) the security of data processing;
(e) the handling of internal whistleblowing reports;
(f) matters relating to the international transfer of data; and
(g) notification and prior approval requirements.
Data Retention and Deletion
Subject to any other requirements under applicable local law, the information collected shall be deleted:
(h) immediately if the report falls outside the scope of the Whistleblowing Policy, is found to be unfounded, or if no internal action is taken in response to the reported concern;
(i) immediately after the case has been closed by the competent authorities, where the report has been referred to the police or another competent authority;
(j) two months after the conclusion of the investigation if no further action has been taken;
(k) no later than five years after the termination of the employee’s employment. However, where disciplinary measures have been taken against the employee concerned on the basis of the information collected, or where there are other objectively justified reasons requiring the retention of such information, the information shall be retained in the employee’s personnel file.