Home/Whistleblower Policy/

Whistleblower Policy

1. Purpose – Why?

Our company values and codes of conduct are outlined in the Accent Code of Conduct & Ethics. Through our Code of Conduct & Ethics, we aim to establish the corporate values and principles that guide our professional and personal behavior, committing ourselves to fulfilling our mission ethically. This procedure provides an additional framework for whistleblowing in alignment with our vision and principles, as described in the Code of Conduct & Ethics. It outlines a framework for internal reporting and follow-up of suspected misconduct. We firmly believe that everyone can and should raise awareness if they genuinely believe in good faith that unethical practices or misconduct are taking place. This policy was also adopted to implement Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law, as well as the Belgian legislation that transposes the Directive into national law. The general aim of the European Directive and Belgian law is to protect whistleblowers from retaliation of any kind 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. Specifically, Accent's management holds a significant responsibility to act in accordance with our core values and policies. They must not only set an example but also support their team members in upholding these principles.

2. Scope – Who?

In accordance with the European Directive and Belgian legislation, Accent's Whistleblower Policy applies not only to current and future employees but also to former employees, self-employed individuals, shareholders, persons on governing, managerial, or supervisory boards, volunteers, paid or unpaid interns, applicants, and anyone working under the supervision and direction of contractors, subcontractors, and suppliers. Accordingly, the internal reporting channels described in this policy will be made available to all these parties, all of whom will be protected by Accent from retaliation. In this Whistleblower Policy, Accent refers to Accent Jobs for People NV, Accent Construct NV, and Accent Group NV.

3. Misconduct – What?

This Whistleblower Policy applies to all suspected or actual (attempted) unlawful, unethical, or illegitimate conduct relating to Accent (hereinafter "reportable breaches").

Under this policy, the following types of reportable breaches are distinguished:

1) Breaches within the scope of the European Directive and Belgian law, including breaches related 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 harming the financial interests of the Union and/or related to the internal market;
  • Food and feed safety, animal health, and welfare;
  • Public health;
  • Consumer protection;
  • Privacy and personal data protection, and network and information systems security;
  • Social fraud;
  • Tax fraud;
  • Radiation protection and nuclear safety;

Accent's Whistleblower Policy applies not only to workplace breaches in public and private spaces but also to breaches related to work-related activities, including but not limited to:

  • During conferences, seminars, or training sessions;
  • During work-related travel;
  • At after-work events;
  • Via work-related communication;
  • In employer-provided accommodation, such as housing for workers;

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

4. Blow the Whistle! – How?

Breaches of Union law must be identified, addressed, and remedied at an early stage. Providing channels for reporting breaches or misconduct ("whistleblowing") is essential.

This Whistleblower Policy aims to provide internal channels for reporting observations or findings of (suspected) breaches relating to Accent without having to follow the hierarchical route or usual reporting channels. It is not a replacement for but a supplement to existing procedures for handling (individual) complaints or irregularities. Whistleblowing channels are established to report (attempted) unlawful, unethical, or illegitimate behavior when it cannot be reported through usual channels, such as the direct supervisor, HR manager, or another designated person.

We encourage all Accent employees, former employees, self-employed individuals, shareholders, persons on governing, managerial, or supervisory boards, volunteers, interns, applicants, and anyone working under the supervision and direction of contractors, subcontractors, and suppliers to report any form of suspected or actual breaches or misconduct through the dedicated internal channels implemented by Accent. We take all reports seriously and are committed to investigating each one.

You can report in various ways:

  • If possible, discuss the issue with your case manager in person, by phone, or by email:

Melissa Goossens
HR Legal Expert
melissa.goossens@accentjobs.be
+32 470 99 25 18

Joke Vancoppernolle
Company Lawyer
joke.vancoppernolle@accentjobs.be
+32 496 71 35 52

If you are unable to do so, you can report the misconduct through our reporting tool (SPOT). SPOT allows you to report actual or suspected misconduct in an accessible and, if desired, anonymous manner. The tailored workflow within SPOT guides whistleblowers through the entire process. Each issue is handled and followed up according to existing escalation procedures. Access the tool via talktospot.com/hohr or via the QR code.

While Accent hopes that reporting a concern through internal reporting channels will provide sufficient relief and therefore is the preferred option, there may be circumstances where it is more appropriate to report a concern directly to an external body. 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 case manager will also inform you whether the report is considered potential misconduct or a matter that should be handled through standard reporting procedures. If deemed necessary, the case manager, together with the whistleblower committee (composed of a company lawyer, HR Legal Expert, Audit Manager, and Operations Manager), will investigate the contents of the report.

During the investigation, the case manager may contact you (via SPOT or, if possible, directly) for further clarification. As required by the European Directive, Accent must respect the rights of the individuals mentioned in the report to be heard and their right to access their file, while maintaining the anonymity and confidentiality of the report and the whistleblower without jeopardizing the investigation.

Within three months of the acknowledgment of receipt, the case manager will, to the extent possible and with respect to any applicable confidentiality or privacy requirements concerning individuals mentioned in the report, provide the whistleblower with an update on the progress of the investigation and any mitigating measures taken.

All reports are treated confidentially, and information is shared only on a 'need-to-know' basis. The data related to each report is not retained longer than necessary and appropriate to comply with the requirements of the Directive.

All personal data processed by Accent under this Whistleblower Policy is handled in compliance with applicable legislation and is used solely to fulfill the objectives of this policy.

6. Non-Retaliation

The identity of the whistleblower and all other information from which the whistleblower's identity can be directly or indirectly inferred will be kept confidential as much as possible. This information may only be disclosed when necessary and proportionate obligations are imposed by Union or national law in the context of investigations by national authorities or judicial proceedings. If information is disclosed, the whistleblower will be informed before their identity is revealed, unless such notification would jeopardize the relevant investigation or judicial process.

A whistleblower who acts in good faith and on reasonable grounds ("justified reasons"/"motifs raisonnables") is protected by this Whistleblower Policy against retaliation. There are no repercussions for reporting a (potential) violation in good faith and on reasonable grounds, even if the report is later found to be unfounded. This means that the whistleblower must not be disadvantaged in any way as a result of their report.

If the whistleblower demonstrates that they have been penalized, treated unfairly, or otherwise disadvantaged as a result of their report, it is presumed that the harm was inflicted as retaliation for the report unless the person taking the adverse action can prove that the measure was based on justified reasons and was unrelated to the act of reporting. If the investigation reveals that a report was made falsely or in bad faith, this may be grounds for taking appropriate and reasonable measures against the whistleblower. Disciplinary action, including dismissal, may be taken against anyone who violates the provisions of this policy.