Whistleblower Policy

1.    Objective – Why?

Our corporate values and behavior guidelines are outlined in the JobRoad Code of Conduct & Ethics. With our Code of Conduct & Ethics, we aim to outline the corporate values and principles in our professional and personal behavior and commit ourselves to fulfilling our mission in an ethical manner.
This procedure provides an additional framework for our vision and principles in the context of whistleblowing, as described in the Code of Conduct & Ethics. It provides a framework for internal reporting and follow-up of suspected misconduct. We believe that everyone can and should raise awareness if they sincerely believe that unethical practices or misconduct are occurring.
This policy has also been adopted to implement Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law as well as Belgian legislation transposing the Directive into national law. The general purpose of the European directive and Belgian law is to protect whistleblowers against retaliation in any form and to require public and private organizations to establish formal procedures for internal reporting and follow-up of reports.
We emphasize that everyone has a responsibility to contribute to and maintain a culture of transparency and openness, free from retaliation. In particular, JobRoad management bears a significant responsibility to act in accordance with our core values and policies. They must not only set a good example but also support their team members in their efforts to uphold these principles.

2.    Scope – Who?

In accordance with the European directive and Belgian legislation, JobRoad’s Whistleblower Policy applies not only to current and future employees but also to former employees, freelancers, shareholders, and persons who are part of the administrative, managerial or supervisory body, volunteers, and paid or unpaid interns, applicants, and all persons working under the supervision and direction of contractors, subcontractors, and suppliers.
Consequently, the internal reporting channels described in this policy will be made available to all the aforementioned parties, all of whom will be protected by JobRoad against retaliation.

3.    Misconduct – What?

This Whistleblower Policy applies to all suspected or actual (attempted) illegal, unethical, or illegitimate behavior related to JobRoad (hereinafter referred to as “reportable breaches”).
In the context of this policy, a distinction is made between the following types of reportable breaches:

1)    Breaches that fall within the scope of the European Directive and Belgian law, namely breaches relating to:
•    Public procurement;
•    Financial services, products and markets, and prevention of money laundering and terrorist financing;
•    Product safety and compliance;
•    Transport safety;
•    Environmental protection;
•    Breaches that harm the financial interests of the Union and/or relate to the internal market;
•    Food and feed safety, animal health and welfare;
•    Public health;
•    Consumer protection;
•    Protection of privacy and personal data, and security of network and information systems;
•    Social fraud;
•    Tax fraud;
•    Radiation protection and nuclear safety;

JobRoad’s Whistleblower Policy applies not only to breaches in the workplace, in public and private spaces, but extends to breaches related to all work-related activities such as (not limited to):
•    During conferences, seminars or training sessions
•    During work-related travel
•    During after-work events
•    Via work-related communication
•    In employer-provided accommodation, such as when providing housing facilities to people at work

JobRoad emphasizes and commits to protecting all individuals who in good faith report suspected or actual (attempted) breaches against retaliation.

4.    Blow the whistle! – How?

Breaches of Union law must be detected, addressed, and corrected at an early stage. Providing channels for reporting breaches or misconduct (“whistleblowing”) is essential.

This Whistleblower Policy is intended to provide internal channels for reporting observations or findings of (suspected) breaches related to JobRoad without having to follow the hierarchical route or usual channel. It is not a replacement but a supplement to existing procedures for handling (individual) complaints or irregularities. Whistleblower channels are set up to report (attempts at) illegal, unethical, or illegitimate behavior when these cannot be reported through usual channels, such as the direct supervisor, the HR manager, or another regularly designated person.

We encourage all JobRoad employees, former employees, freelancers, shareholders, persons who are part of the administrative, managerial, or supervisory body, volunteers and interns, applicants, and all persons working under the supervision and direction of contractors, subcontractors, and suppliers, to report any form of suspected or actual breaches or misconduct through the special internal channels that JobRoad has implemented. We take all received reports seriously and are committed to investigating each report.

You can report in various ways:
If possible, discuss the issue with your reporting manager in person, by phone, or via email

Melissa Goossens
HR Legal Expert
+32 470 99 25 18

Joke Vancoppernolle
Company Lawyer
+32 496 71 35 52

If you are unable to do so, you can report the misconduct through our reporting tool (SPOT):

With Spot, you can report actual or suspected misconduct in an accessible and, if desired, anonymous manner. The customized workflow within Spot guides whistleblowers through the entire process. Each issue is handled and followed up according to existing escalation procedures. Open the tool via talktospot.com/hohr or via the QR code.

Although JobRoad hopes that reporting a concern through internal reporting channels provides sufficient relief and is therefore preferred, there may be circumstances in which it is more appropriate to report a concern directly to an external authority. If applicable, you can report your concern directly to the Federal Ombudsman.

5.    Handling and investigation

For each report, you will receive an acknowledgment of receipt within seven calendar days. The reporting manager will also inform you whether the report is being assessed as potential misconduct, or if it is a matter that should be handled through the usual reporting procedures. If deemed necessary, the reporting manager, together with the whistleblowing committee (composed of: company lawyer, HR Legal Expert, Audit manager, and the operations manager), will investigate the content of the report.

During the investigation, the reporting manager may also contact you (via SPOT or, if possible, directly) for further clarification. As required by the European Directive, JobRoad must respect the right of the individuals named in the report to be heard and their right to access their file, taking into account the anonymity and confidentiality of the report and the reporter without jeopardizing the investigation.

Within three months of the acknowledgment of receipt, the reporting manager will, as far as possible and taking into account any applicable confidentiality requirements or privacy issues concerning anyone who is the subject of the report, report back to the reporter on the status of the investigation and any mitigating measures taken.

All reports are treated confidentially and information is only shared on a ‘need to know’ basis. The data of each report is not kept longer than necessary and appropriate to meet the requirements of the Directive.

All personal data processed by JobRoad under this Whistleblower Policy is carried out in accordance with applicable legislation and is used solely to achieve the objectives of this policy.

6.    Non-retaliation

The identity of the reporter and all other information from which the identity of the reporter can be directly or indirectly inferred will be kept as confidential as possible. This information may only be disclosed when it is a necessary and proportionate obligation imposed by Union or national law within the context of investigations by national authorities or judicial proceedings. If information is disclosed, the reporter will be informed before their identity is disclosed, unless that information would jeopardize the relevant investigation or judicial proceedings.

The reporter who acts in good faith and on reasonable grounds (“reasonable grounds”/”motifs raisonnables”) is protected by this Whistleblower Policy against retaliation. There are no repercussions for reporting a (possible) breach in good faith and on reasonable grounds, even if the report subsequently proves to be unfounded. This means that the reporter cannot be disadvantaged in any way as a result of their report.

If the reporter demonstrates that they are being punished, unfairly treated, or otherwise disadvantaged as a result of their report, it is assumed that the harm was caused as retaliation for the report unless the person taking the negative action can prove that the measure was based on justified reasons and had no connection with the reporter’s act of reporting. If the investigation reveals that a report was made falsely or in bad faith, it may be grounds for taking appropriate and reasonable measures against the reporter. Disciplinary measures, including dismissal, may be taken against anyone who violates the provisions of this policy.

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