Whistleblowing procedure

A whistleblower is a person who works within an organization, or who is in contact with an organization as part of his or her professional activities, and who reports illegal, unethical or dangerous activities within an organization. The wrongdoing that the whistleblower discloses must be in the public interest, not personal, and must fall within the professional sphere.

Anyone who is aware of information concerning a breach of integrity in a professional context.

They may be current or former employees, interns, volunteers, self-employed workers, board members, suppliers, subcontractors or customers.

For staff members, unless it is not possible or appropriate, for whatever reason, you must promptly inform your manager, your prevention consultant (psychosocial aspects) or the fraud investigation department (investigations@proximus.com).

If, on the other hand, you make a whistle-blowing report, you do not need to inform your manager.

Violations of integrity of which you are aware in a professional context within the Proximus Group.

You can report violations or potential violations of laws and regulations that fall within the scope of national rules, as well as violations or potential violations of the Proximus Group Code of Conduct or other company policies. It is important to report any potential violation, for which the whistleblower has grounds or evidence, in order to react without delay and thus preserve our company's reputation.

We examine each report independently and impartially on a case-by-case basis because, as stated in our Code of Conduct, the fundamental rules and principles underpinning our commitment to being a socially and ethically responsible company are strong corporate values designed to support our business strategy of creating real and lasting value, and therefore constitute rules of good management. As our Code of Conduct also states, everyone has a responsibility to contribute to the promotion of a healthy corporate culture, and this whistleblowing procedure is a further tool in the service of this commitment, enabling people who witness a breach of integrity to report it, without fear of reprisal, so that action can be taken to put an end to it and prevent further breaches.

Violence, moral and sexual harassment in the workplace. This type of complaint should be addressed to your organization's contact person or prevention consultant (law of August 4, 1996 on the well-being of workers during the performance of their work); - Discrimination. Complaints about discrimination should be addressed to Unia (Interfederal Center for Equal Opportunities) or the Institute for the Equality of Women and Men (anti-discrimination laws), as appropriate.

Reporting can be done internally, externally or through public disclosure.

Internally, there are several ways to report a problem:

1. IT tool processed by an external subcontractor, Grant Thornton
2. By telephone on 0800 45 002
3. By letter to the Group Compliance Manager or to the Chairman of the Audit Committee
4. In person with the Group Compliance Manager

Externally, reports must be made via the federal ombudsman.

Public disclosure is also possible in specific cases.
 

The answer is NO. As a whistleblower, the law automatically protects you from reprisals if you have followed the procedure, even if at the end of the investigation your report turns out to be inaccurate or unfounded. You do not risk sanctions for reporting via the three types of reporting, as the law protects whistleblowers who, in good faith, report a concern.

Any form of retaliation against a whistleblower is punishable by law, and may also result in disciplinary action against the person who took the retaliatory measures, whatever their hierarchical level within the organization.

You'll also be protected if the concern you're reporting concerns a line manager, executive or member of top management.

Protection against retaliation will not apply, however, if you yourself are involved in the reprehensible act, if you have voluntarily made a false report, or if you have voluntarily transmitted false or dishonest information.

You can also contact the Group Compliance Manager directly, on an anonymous basis, if you wish. He is bound by professional secrecy, which is a legal obligation. You can also seek assistance from the Federal Institute for Human Rights (IFDH), which has been designated by law as the central information point for whistleblowing regulation in Belgium.

Yes, you can choose to remain anonymous, as guaranteed by Belgian law. Proximus guarantees anonymity by using channels such as an external tool managed by an independent team that does not allow the user to be traced.

You will remain anonymous throughout the process (reporting, analysis, closure) and after the file has been closed.

If you choose to identify yourself, your identity will be kept confidential. This is provided for by law, which protects you against any kind of reprisal.

Once you have reported a violation via one of the channels provided, you will receive a confirmation of handling within seven days. Your report will then be subject to an appropriate investigation. Within 3 months of acknowledging receipt of the report, you will receive follow-up feedback.

Examples of reports:

1. A call for tenders is in progress and my colleague informs me that he has invited the potential client for a meal in order to build the relationship and better understand his needs - this is forbidden by the "Anti-corruption and conflict of interest" policy and I point it out;
2. I know that my colleague has a sideline that requires him to visit customers after work. I am aware that he uses the PC and mobile phone provided by Proximus to manage his additional activity - this is prohibited by the "Use of company equipment" and "Anti-corruption and conflict of interest" policies and I am reporting it;
3. At a conference, I overhear my colleague discussing with a competitor the possibility of matching the price of a product, in order to keep a comfortable margin - this is forbidden by competition policy and I point out;
4. I notice that my colleague is recording sales for friends who are already Proximus customers as sales to new customers in order to pass on offers addressed to them. This is fraud and I'm reporting it.

Report this immediately to the Group Compliance Manager. You can also go directly to the external reporting channel, the Integrity Center of the Federal Ombudsman, appointed by law to receive and investigate this type of complaint.

• Maurizio Carlone
• Email : group.compliance@proximus.com