ADPO NV sets high standards for openness and integrity. In this context, ADPO NV encourages employees who are concerned about a (suspected) breach of the Code of Conduct to report it and raise their concerns without fear of sanctions and/or unfair treatment.

An individual reporter is not expected to be able to prove that an allegation is justified. However, they must be able to demonstrate that there are sufficient grounds to believe that something is wrong.

We distinguish, on the one hand, breaches of a psychosocial nature, for which employees may contact the designated confidential advisers in accordance with the existing procedure on the prevention of violence, bullying and unwanted sexual behaviour at work.

On the other hand, ADPO NV has developed this “Reporting Irregularities” procedure to address specific concerns about (suspected) wrongdoing. This procedure ensures that employees can report observed irregularities without fear of retaliation and that these findings are handled in a consistent manner.

As a general rule, reports or suspicions of integrity breaches should preferably first be discussed with the direct manager or their hierarchical superior. This procedure is therefore intended as a last resort when no other options are available for raising the matter.

Scope

This procedure covers all possible breaches of the ADPO NV Code of Conduct and any suspicion of a breach of applicable legislation and/or a criminal offence, such as:

• Corruption, bribery, extortion and other criminal offences
• Breaches of laws and regulations
• Deliberate circumvention of internal procedures and regulations
• Knowingly providing stakeholders with incorrect or unlawful information
• Deliberate breaches of information security
• Knowingly withholding, destroying or manipulating information about facts that could cause damage to ADPO NV.

ADPO NV takes all reports concerning (suspected) breaches seriously. These will be handled fairly and correctly and in complete anonymity, unless otherwise agreed.

Confidentiality and protection

Confidentiality
All reports are treated confidentially. Everyone directly or indirectly involved in handling a report of a (suspected) integrity breach is bound by a duty of confidentiality with regard to everything entrusted to them or otherwise brought to their attention in connection with it.

Prevention of sanctions or unfair treatment

Reporters who act in accordance with this procedure can make a report without jeopardising their employment-law position. This means that they will not be disadvantaged in any way in their position as a result of this enquiry or report, provided that they act in good faith.

Retaliation against reporters as a result of a genuine report is considered a serious breach of this procedure and the ADPO NV Code of Conduct. In such cases, appropriate action will be taken to protect the reporter’s employment-law position and to sanction those responsible for the retaliation.

Employees who believe they have suffered adverse consequences as a result of a report are requested to inform management as soon as possible.

How to make a report?
A report can be submitted in the following ways:

• E-mail: klokkenluider@adpo.com
• In person: In a sealed envelope addressed to Management
• By telephone: +32 3 570 64 42

Investigation process

1. Acknowledgement of receipt: Within 7 working days of the report.
2. Investigation: The report is investigated by the designated team.
3. Conclusion and Action: Appropriate measures are taken where necessary.
4. Feedback: Where possible, the reporter is informed of the outcome.

Misuse of the procedure
ADPO NV assumes that reporters will raise their concerns in good faith. If a subsequent investigation does not confirm certain reports, or if they prove to be unfounded, no measures will be taken against reporters who raised their concerns in good faith.

Intentionally false reports will have disciplinary consequences for the reporter concerned, and they may be held liable for damage suffered by people affected by those false reports.

Contact
Chair of the Audit Committee: By letter and confidentially
For the attention of the Chair of the Audit Committee
Steenlandlaan 3 – 9130 Kallo

This procedure has been drawn up in accordance with Belgian legislation and European guidelines on whistleblowing.