Updated at February 12th, 2025
Article 1. Why a whistleblowing policy?
This whistleblower policy (also: whistleblower policy) aims to provide both internal employees and third parties who – in a work-related context – become aware of infringements committed by Brayton Global to European Union law or breaches that the Belgian legislator has added to the scope of application of the Belgian Whistleblower Act (see the list under Article 3 below), the possibility to report them (hereafter: whistleblower), without having to fear retaliation.
Brayton Global is setting up an internal reporting channel for this purpose. Anyone wishing to make a report within the scope of the Whistleblower Act, will initially use the internal reporting channel for this purpose.
Article 2. Definitions
In these regulations, we mean by:
- Infringement: acts or omissions that:
- are unlawful and relate to Union acts and policies falling within the material scope referred to in Article 3, or
- undermine the purpose or application of the rules in the Union act and policy areas falling within the material scope referred to in Article 3.
- Breach information: information, including reasonable suspicions, about actual or potential breaches, which have occurred or are highly likely to occur within
- Brayton Global where the reporter works or has worked or with whom the reporter has had contact by virtue of his work, as well as about attempts to conceal such breaches.
- Report: the oral or written provision of information about breaches.
- Internal reporting: communicating information about breaches orally or in writing within Brayton Global.
- External reporting: the oral or written communication of information about breaches to the competent authorities.
- Disclosure: the oral or written public communication of information about breaches.
- Reporter: a natural person who reports information about breaches (internal, external or public) obtained in the context of his work-related activities.
- Data subject: a natural or legal person named in the report (internal, external or public) or disclosure as a person to whom breaches are attributed or with whom that person is associated.
- Facilitator: a natural person who assists a reporter in the reporting process in a work-related context and whose assistance must be confidential.
- Retaliation: a direct or indirect act or omission that occurs in a work-related context as a result of an internal or external report or disclosure, and which results or may result in unjustified harm to the reporter (or to facilitators or third parties associated with the reporter).
- Follow-up: action by the recipient of a report or a competent authority to verify the accuracy of the allegations made in the report and address the reported breach if necessary.
- Feedback: providing the reporter with information on the action planned or taken as a follow-up and the reasons for that follow-up.
- Competent authority: the Belgian authority designated to receive reports in accordance with Article 5 of this policy and to provide feedback to reporters and ensure follow-up.
- Work-related context: current or past employment activities in the private sector through which, regardless of the nature of those activities, individuals may obtain information about violations and where those individuals may face reprisals if they were to report such information.
- Federal coordinator: the authority responsible for coordinating external reporting for the private sector in accordance with Section 4 Chapter 4 of the Whistleblowing Act.
- Reporting manager: the impartial person or department authorised to follow up on reports, maintain communication with the notifier, may request additional information from the notifier, if necessary, provide feedback to the notifier and receive notifications where applicable.
Article 3. Notifications
The internal reporting channel can be accessed 24/7 by:
- employees
- anyone who, in a work-related context, becomes aware of breaches of European Union law and/or breaches that the Belgian Legislator has added or will add to the scope of the Belgian whistleblowing regulation.
“Work-related context” means that in addition to (former) employees, trainees, suppliers, self-employed persons, shareholders, job applicants and so on who cooperate with Brayton Global in a sustainable way can also make a report.
Specifically, a reporter can report breaches or matters that they believe in good faith to be breaches in any of the following areas:
- public procurement;
- financial services, products and markets, prevention of money laundering and terrorist financing;
- product safety and product conformity;
- transport safety;
- protection of the environment;
- radiation protection and nuclear safety
- food and feed safety, animal health and animal welfare;
- public health;
- consumer protection;
- protection of privacy and personal data, and security of network and information systems;
- infringements affecting the financial interests of the European Union;
- internal market infringements (competition and state aid; corporate tax infringements; constructions aimed at unfairly obtaining a tax advantage.
- combating tax fraud
- combating social fraud
Article 4. Internal reports
4.1 Reporting channel and access
A person who identifies a breach or has reasonable suspicions that a breach has occurred or will occur that violates one or more of the areas mentioned in Article 3, and in which Brayton Global is involved, can always report it through the most appropriate and accessible channel.
Within Brayton Global, a reporter has the following options for this purpose:
- Notification by e-mail to via whistleblowing@braytonglobal.com (subject: Brayton global – Whistleblowing).
- Reporters may also request to report a breach through a physical meeting within a reasonable time. Such a physical report can also be made by appointment at whistleblowing@braytonglobal.com
The information concerning the availability of this email address is available on the Brayton Global’s website: https://www.braytonglobal.com/
4.2 Handling of internal reports
The internal reporting channels at Brayton Global are managed externally.
A confirmation of receipt will be sent to the reporter within seven days of receiving the report at the latest. An impartial person or department will be responsible for following up the report and communicating with the reporter.
Through the external management of the reporting channel, the risk of conflicts of interest is reduced to a strict minimum. If necessary, external investigation resources can be used.
4.3 Disclosure to public authorities
If a report contains information to be transmitted by operation of law to a government agency responsible for following up crimes within the areas of Article 3 aforementioned,
the person or department following up the report within Brayton Global will, after thorough consultation with Brayton Global, forward the information to the relevant government agency.
4.4 Feedback
The reporter receives feedback on the handling of the report. This means that he receives information about the corrective actions taken or not taken, process improvements or changes and/or other further steps. This feedback does not include details about specific individuals and can therefore be rather general in nature.
If additional investigation is necessary or appropriate, Brayton Global will guard the confidentiality of the investigative acts and respect for the rights of third parties.
Within a reasonable time, and no later than three months after the sending of the acknowledgement of receipt, or if no acknowledgement of receipt was sent to the reporter, three months after the expiry of the seven-day period following the report, the reporter will receive information on the actions planned or taken as a follow-up and on the reasons for such follow-up.
If it is not possible to provide the reporter with any feedback, the reporter will be informed of this, as well as the reason why information is not yet available.
Article 5. External notifications
5.1 External reporting channels
The reporter who does not want to make an internal report can also use an external reporting channel.
External reports can be made to the federal coordinator for external reports. The reporter has the following options:
- reporting by telephone on the telephone number 0800/99961; or
- by email integriteit@federaalombudsman.be; or
- via the website form https://www.federaalombudsman.be/nl/klokkenluiders/meld-een-integriteitsschending-of-inbreuk-op-dewetgeving
The reporter can also request to report a breach via a physical meeting within a reasonable period of time. Such a physical report can be made by appointment (by phone or email) with the federal coordinator of the competent authority. The reporter can also contact the competent authority.
5.2 Handling of external reports
Within seven days of receiving the report at the latest, the reporter will be sent an acknowledgement of receipt by the competent federal department.
Within a reasonable period, and at the latest three months after sending the acknowledgement of receipt, or if no acknowledgement of receipt was sent to the reporter, three months after the expiry of the period of seven days after the notification, the reporter will receive information from the competent federal department about the measures planned or taken as a follow-up and about the reasons for this follow-up.
In exceptional justified cases, this period may be six months.
The competent authorities and the federal coordinator designate the staff members responsible for handling the notifications, and in particular for:
- providing information on the reporting procedures to interested parties.
- receiving and following up reports.
- maintaining contact with the reporter to provide feedback and request further information if necessary.
These staff members are bound to confidentiality and will receive specific training on how to handle reports.
Article 6. Disclosure
A person making a disclosure is eligible for protection under the Whistleblowing Act if the following conditions are met:
- in the case of an indirect disclosure: the person first made an internal and/or external disclosure, but no appropriate action was taken as a result of that disclosure within the specified period; or
- in the case of a direct disclosure: the person has reasonable grounds to believe that:
- the breach may pose an imminent or real danger to the public interest; or
- there is a risk of retaliation in an external report, or the breach is unlikely to be effectively remedied, due to the particular circumstances of the case, because, for example, evidence may be withheld or destroyed, or an authority may collude with the perpetrator of the breach or be involved in the breach.
This does not apply to cases where a person provides information directly to the press under specific provisions establishing a system for the protection of freedom of expression and information.
Article 7. Confidentiality and secrecy
Brayton Global will ensure that the information on the report is kept in such a way that it is physically and digitally accessible only to those designated by Brayton Global as authorized persons. All reports and subsequent investigation reports and/or determination reports, decisions …, are treated with the utmost confidentiality.
Brayton Global maintains a strict ‘need to know’ basis for disclosing relevant information to employees or third parties. All employees involved in receiving reports, or following up on reports, will maintain strict confidentiality about the content of reports, reports, decisions … and to the extent permitted by applicable law.
Article 8. Protection
8.1 Protection against retaliation
Brayton Global guarantees that the reporter will be protected from retaliation, including threats and attempts to retaliate (see below), if the reporter acts in good faith and follows the correct path when making a report.
The “right way” means that, in the first instance, the reporter uses the provided internal reporting channels as much as possible. Only if there is no internal channel, or if an external report goes unheeded, can a report be made public.
By “retaliation” we mean, among other things:
- suspension, temporary retirement, dismissal or similar action.
- demotion or refusal of promotion.
- transfer of duties, change of job location, reduction in pay, change in working hours.
- withholding of training.
- negative performance appraisal or employment reference.
Contact Us
Don’t hesitate to contact us if you have any questions.
- Via Email: whistleblowing@braytonglobal.com