At GD Group (“Company”) we are guided by our company values. These values are the foundation of how we conduct ourselves and interact with each other, our clients, members, suppliers, shareholders and other stakeholders.
Our Company is committed to ensuring corporate compliance and to conducting business with integrity, honesty and fairness, with respect for the law and our values.
In spite of this commitment, you may one day observe conduct that concerns you, or that seems to violate the company values or its policies. If you observe or suspect such misconduct, you are encouraged to speak up. By doing so, you give our Company the opportunity to deal with the issue. Remaining silent about possible misconduct may worsen a situation and undermine trust. Speaking up is essential for us to sustain our reputation, success and ability to operate – both now and in the future.
This Speak Up policy (“Policy”) has been put in place to ensure any concerns raised regarding misconduct or improper state of affairs or circumstances in relation to the Company’s business are dealt effectively, securely and appropriately. And to describe what you can expect from our Company if you speak up.
Our Company encourages the reporting of any instances of suspected unethical, illegal, corrupt, fraudulent or undesirable conduct involving the Company’s business and provides protections and measures to individuals who make a disclosure in relation to such conduct without fear of retaliation.
This Policy is available to all employees of the Company and will be provided to the new employees and officers upon commencement of their employment or engagement.
This Policy applies to any person who is, or has been, any of the following with respect to the Company:
This Policy is intended to apply to the above persons in all countries in which the Company’s subsidiaries operates a business. However, any local Speak Up policy (“Local Policy”) under the requirements of the relevant EU and national legislation prevails on this Policy and will be applicable to the above-mentioned persons working for or interacting with the relevant subsidiary.
You may make a report or disclosure under this Policy if you have reasonable grounds to believe that a Company director, employee, contractor, supplier, consultant or other person who has business dealings with the Company has engaged in any misconduct (“Reportable Conduct”).
Examples of Reportable Conduct are:
For the avoidance of doubt, Reportable Conduct does not include personal work-related grievances. A personal work-related grievance is a grievance about any matter in relation to a staff member’s current or former employment, having implications (or tending to have implications) for that person personally and that do not have broader implications for the Company.
Examples of personal work-related grievances are as follows:
Personal work-related grievances should be reported to your manager or in accordance with the Grievance Policy (if applicable in the relevant subsidiary).
This Policy allows you to disclose Reportable Conduct through a variety of channels. If you suspect such misconduct, you are encouraged to address this directly with the person involved. If this would not be appropriate, please feel free to make a disclosure under this Policy.
As a general guideline, the first person to approach when raising a concern is your line manager. In addition, you can approach a director or, if your concern is related to a director, the Company’s Supervisory Board. You may also choose to discuss your concern with your Human Resources representative, Confident or Legal function.
If you suspect Reportable Conduct and genuinely believe that the matter cannot be dealt with through the available channels within your company, you can use our Group Speak Up Service (speakup@gd-group.org) to make a written disclosure of the Reportable Conduct confidentially. We encourage you to make the disclosure in English, but you can also choose to do it in your own language.
We strongly encourage you to raise concerns internally through one of the available channels. Taking a concern to an outside party (e.g. the media) can have serious implications for our Company, for the persons involved and possibly also for yourself. By speaking up internally, you give our Company the chance to look into the matter and act if needed. In this way we can truly improve our Company together.
We encourage you to speak up as soon as possible, ideally before situations get out of hand or damage is done. It is always better to discuss upfront than to report afterwards. If you know about or suspect misconduct, speak up with the facts that you have. We do not expect you to have all the answers and you are certainly not expected to prove that your concern is well founded. Let our Company look into the matter to determine if there is a reason for concern.
Never investigate the matter yourself and do not seek evidence to build a strong case. We guarantee that no disciplinary measures or other steps will be taken against you if your genuine disclosure later turns out to be mistaken or misguided.
All reporting is done confidentially. This means that information about your concern will only be shared with a limited number of people on a strict need-to-know basis. Information will only be disclosed outside this small group if we are required to do so by law or an important public interest is at stake. In principle, we are obliged to inform the implicated person that a complaint has been filed against him/her, but your identity will not be disclosed. You yourself can help us protect confidentiality by being discreet and not discussing your report with your colleagues or anyone else.
We do encourage you to reveal your identity as it is more difficult, and in most circumstances even impossible, for us to properly investigate the matters disclosed anonymously.
Our Company is committed to protecting the privacy of everyone involved. We will do everything to safeguard personal data from unauthorized access and processing. Any personal data obtained as part of this Policy will only be used for the purposes explained in this Policy or to comply with the law or an important public interest. Please find more details on the protection of personal data in the Company’s privacy statement.
In our Company we encourage people to speak up about (suspected) misconduct and employees are always protected when they address a concern. Please feel confident that you will not suffer for raising concerns in good faith about suspected misconduct. Any form of threat or retaliation will not be tolerated. Retaliation against reporters is treated as a violation of our policy and consequently may lead to disciplinary measures.
You will not be protected, however, if you maliciously raise a concern that you know is false.
Our Company takes every report of possible misconduct seriously. If you make a disclosure, you will receive a confirmation of receipt within 7 calendar days, with an estimate of how long it will take to handle and assess your disclosure. Your report will undergo an initial review, and if necessary, it will be appropriately investigated. On average, closure of the matter can be expected within 2 months. You will be informed of the overall findings, i.e. whether or not our Company has established that misconduct has taken place.
We will not be able to give you full details of the outcome of a case (or related actions taken) for reasons of confidentiality, privacy and the legal rights of all concerned.
Our Company follows a two-phased approach when investigating a disclosure:
All initial reviews and investigations will be conducted in a fair, unbiased and timely manner with respect to all parties involved and in accordance with relevant laws and principles (including fair hearing) and all reasonable efforts will be made to preserve confidentiality during the review and investigation. Details of the case, your identity and the identity of anyone else mentioned in the report, are kept confidential throughout and after the investigation and are only shared on a need-to-know basis.
The person against whom any allegations have been made will also be informed of the disclosure and will be provided with an opportunity to respond (unless there are any restrictions or other reasonable bases for not doing so).
If you become involved in an investigation, you need to cooperate and answer all questions completely and honestly. Lying to the people performing the investigation as well as delaying, interfering with or refusing to cooperate with an investigation may lead to disciplinary measures. All parties involved, including the accused, are entitled to confidentiality in order to avoid unnecessary damage to their reputation. Therefore, if you participate in or learn about an investigation, you must keep the matter confidential.
If your disclosure is well-founded (i.e. misconduct has indeed taken place), appropriate measures will be taken where necessary in accordance with the law and our policy on disciplinary measures.
If you believe that your disclosure or a disclosure against you has not been handled appropriately or that an investigation has not been performed correctly, please inform the Company’s Supervisory Board through the Company Secretary.
If you have questions relating to this Policy or if you need assistance, please contact:
Content owner: Legal Affaires
Person: Annamária Vágási, General counsel and Company Secretary GD Group, annamaria.vagasi@gd-group.org
Effective as per: 28 September 2023
Version: 1.0
Notes: Our Company refers to each company that is majority owned and controlled, directly or indirectly, by GD Group B.V. Amendments can be made from time to time and are communicated. Please note that this Policy has a complementary character: any applicable national legislation remains valid and any local Speak Up policy prevails on this Policy.
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