In line with our values and vision and respecting the interests of our stakeholders, we are committed to preventing and detecting unlawful behaviour. The use of whistleblowing is an effective method in this regard. It enables employees to report suspicions and doubts about abusive activities without fear of reprisals. The Whistleblowing Policy is essential to achieve the following goals:

Promote a culture of openness, accountability and integrity;
Create a safe environment in which whistleblowers can report violations, misconduct or omissions that may affect Vytech Group’s integrity or lead to financial loss or reputational damage without fear of reprisal;
Increase awareness among employees about the existing channels within Vytech Group for reporting suspected or actual breaches;
Increasing the likelihood that management will be alerted to breaches at an early stage and can take appropriate action;
Ensuring confidentiality and protecting the legitimate personal interests of whistleblowers when reporting possible breaches;
Ensure compliance with the principles relating to the investigation procedure as set out in the Whistleblower Policy.

This Whistleblowing Policy is based on the requirements laid down in the EU Whistleblowing Directive (Directive (EU) 2019/1937) and its transposition into local legislation.

In accordance with the Whistleblower Act, reports can be made that are believed in good faith to infringe the following areas:

The scope is defined in Article 2 of the Belgian Whistleblowers Act and includes reports of breaches of European or national legislation in various fields such as public procurement, financial services, product safety, environmental protection, public health, and consumer protection.

Reports may relate to breaches affecting the EU’s financial interests or breaches relating to the internal market.

The competent authorities for external reporting are listed in the Royal Decree of 22 January 2023.

Within seven days of receiving the report, the reporter receives an acknowledgement of receipt. No later than three months after the acknowledgement, the reporter receives feedback on the measures planned or taken and the reasons for them.

Whistleblowers acting in good faith will not be subjected to any retaliation. If the whistleblower is found not to have acted in good faith, disciplinary or legal action may be taken.

If the alleged facts are confirmed, disciplinary measures can range from a warning to dismissal, depending on the severity of the offence. In cases of insufficient evidence, corrective measures may be taken to prevent recurrence.

Whistleblowers who report in good faith will be protected from unjustified reprisals. This includes measures such as suspension, demotion, harassment or discrimination. Complaints of retaliation are taken seriously and investigated if necessary. This protection also applies to persons who have helped the whistleblower.

This Whistleblower Policy does not apply to personal work-related concerns or commercial decisions of Vytech. Regular internal channels should be used for such issues. If the matter cannot be reported through these internal channels, the Whistleblower Policy will apply.