This policy describes the policy and procedure for the reporting of (suspected) serious integrity violations and breaches within Tectum Group NV and is part of the integrity policy through which Tectum Group NV pursues an open and honest corporate culture.
This policy was drafted in the context of the Directive (EU) 2019/1397 dated 23.10.2019 for the protection of persons reporting breaches of Union law, which was transposed into the Belgian Law of 28.11.2022 on the protection of reporters of breaches of Union or national law established within a legal entity in the private sector.
The purpose, who it covers, the types of reports possible, the reporting process and the safeguards, both for the reporter and for the person under investigation, are explained below.
The purpose of this policy is to enable employees and third parties to report (suspected) serious integrity violations and/or breaches.
Tectum Group NV expects all its employees to conduct themselves in accordance with our core values, policies and applicable laws and regulations. This policy describes how employees and third parties can confidentially raise concerns without fear of retaliation, threats and attempted retaliation.
This policy applies to all employees with an employment or self-employed service contract and to all possible third parties who have a relationship with Tectum Group NV, including its current and future subsidiaries active in the roof and facade sector.
More specifically, the following people can make a report: (former) employees, self-employed persons, shareholders, persons belonging to the managerial or supervisory body of a company, including non-executive members, volunteers, paid or unpaid trainees and anyone working under the supervision and direction of (sub)contractors and suppliers of the legal entities of Tectum Group NV.
The following companies are currently part of Tectum Group NV: Tectum Dekkers NV, Tectum Constructors BV, Tectum Roofcomfort NV, Six D&G by Tectum BV, Tectum Plus BV, Tectum Vastgoed BV, Tectum Transport NV, Tectum Distributiecentrum NV, Darubo BV, Davis NV, CPE NV and MAWIPEX BV.
The following integrity breaches or violations identified by whistleblowers may be reported:
I.All possible violations related to:
a. Public procurement;
b. Financial services, products and markets, prevention of money laundering and terrorist financing;
c. Product safety and product compliance;
d. Transportation safety;
e. Protection of the environment;
f. Radiation protection and nuclear safety;
g. Food and feed safety, animal health and welfare;
h. Public health;
i. Consumer protection;
j. Protection of privacy and personal data, and security of network and information systems;
k. Combating tax fraud;
l. Combating social fraud;
Any violation of the legal or regulatory provisions or directly applicable European provisions, as well as the provisions taken in implementation of the aforementioned provisions, falls within the scope of this law.
II. This whistleblowers policy also applies to infringements affecting the financial interests of the Union, as well as infringements relating to the internal market(including infringements of Union rules on competition and state aid).
Reports of (alleged) violations can be submitted to the Integrity Officer via email, letter, telephone, or through the online platform tectumgroup.sdwhistle.com. The online platform is available 24/7 and can be used anonymously. However, anonymous reports must contain sufficient details to be handled. It is also possible to make an external report to the Federal Ombudsman, particularly in situations where no response has been received to an internal report or where there is an imminent or obvious danger to the public interest. Evidence, documents, references, photographs or other relevant information can help any agency to process a report more efficiently.
Integrity Officer
Name: Bastiaan Baeskens (Corporate Counsel)
E-mail: integrity@tectumgroup.be
Phone: 089 62 95 60
Address: Troisdorflaan 6, 3600 Genk
Federal Ombudsman
E-mail: contact@federaalombudsman.be
Address: Leuvenseweg 48/6, 1000 BRUSSELS
Website: https://www.federaalombudsman.be
Phone: 0800 99 961
a. Report
The reporter reports the violation(s) or breach(s) verbally or in writing to the Integrity Officer using the contact information listed above.
b. Receipt notification
The reporter receives an acknowledgement of receipt of his/her report within 7 days of the report.
c.Possible physical meeting with reporter
At the express request of the reporter, a physical meeting may take place between the reporter and the Integrity Officer within a reasonable period of time.
d. Follow-up
The follow-up of reports is done by the Integrity Officer and will maintain communication with the reporter. If necessary, the Integrity Officer may request additional information from the reporter. The Integrity Officer checks the accuracy of the allegations made in the report and considers whether the reported violation can be addressed, including through measures such as an internal preliminary investigation, an inquiry, a prosecution, a recovery, a termination procedure,...
e.Feedback to the reporter
The Integrity Officer is obliged to provide feedback to the reporter on the planned follow-up or measures implemented and the reasons for such follow-up. This feedback will be done within a reasonable time and at the latest 3 months after the notification of receipt.
Reports are treated confidentially, and information is shared only on a need-to-know basis. All personal data is used only in accordance with Tectum Group NV's GDPR policy. Tectum Group NV encourages reporting possible breaches or violations without any adverse consequences for the reporter. Retaliation is considered a serious violation of this policy. The reporter is protected from reprisals, threats and attempted reprisals. The following conditions must be met for the reporter to benefit from this protection:
- There were reasonable grounds for the reporter to believe that the reported information about violations was accurate at the time of the report and that such information falls within the scope of the law;
- The report was made in compliance with the law.
Each reporter must act in good faith. Knowingly reporting or disclosing false information is punishable under Articles 443 to 450 of the Criminal Code.
The person under investigation is also entitled to protection and will be informed within a reasonable time unless it compromises the investigation. Information is kept confidential and shared with a limited number of persons on a need-to-know basis. The person under investigation has the right to respond to allegations and may appeal adverse findings or decisions. Reporting (suspected) unethical or illegal behavior is of great importance to the integrity and reputation of Tectum Group NV and contributes to a culture of openness and accountability. We encourage everyone to report any concerns or worries through the available channels. We are committed to treating reports seriously and carefully, and to maintaining confidentiality. Together we work to provide a safe and ethical work environment for all our employees and third parties.
If you have any questions about this policy, please do not hesitate to contact the Integrity Officer at the contact information provided above.
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