Whistleblowing procedure

Scene 1: Whistle-blower in his car on his way to work. Whistle-blower parked his car in the car park. Proximus considers integrity as one of the corner stones of its DNA.

Scene 2: Whistle-blower notices an astonished work controller watching a worker on a ladder in a wheelbarrow. The boss of the worker is giving cash to the controller and tells him to keep quite about it. You notice wrongdoing or breaches of the Code of Conduct, internal policies and procedures, laws and regulations?

Scene 3: Whistle-blower notices a colleague at a restaurant with a partner. The colleague is being offered plenty of food and wine in front of him.

Scene 4: The same colleague (of the whistle-blower) is with another partner on a yacht and receives a big gift.  The partner and the colleague agree on a contract.  “Participating in” or “closing your eyes on” bribery may lead to disciplinary sanctions, dismissal and criminal prosecution.

Scene 5: The whistle-blower wants to escalate to N+1, but his N+1 is the colleague who happened to be the corrupt employee who went on the yacht and to the expensive restaurant during a bidding or proposal process in the previous scenes.   Not appropriate to escalate to your manager? Use one of the whistleblowing channels!

Scene 6 : The 4 whistleblowing channels are showed:

send an email to whistleblower@proximus.com

make a phone call to the 0800 45 002

write a letter (physical paper with CONFIDENTIAL mentioned on the envelope)

meet physically with the Compliance manager

Scene 7: Compliance manager and Investigations Manager discuss the case (confidential file on desk with CONFIDENTIAL in red) Your concern will be treated in the most confidential manner.

Scene 8: Animation where the whistle-blower receives an email (entitled “Acknowledgment of receipt”) If your identity is known, an acknowledgement of receipt will be sent to you within 7 days.

Scene 9: Compliance manager, Investigations Manager, Head of Legal and HR gather in a meeting room.  The screen shows “blacked name” of whistle-blower… entitled Whistleblowing Case Nr : WB#28  then with a few lines with Mr of who’s name has been made invisible reported concern …. The Whistleblowing Committee (Compliance, Investigations, Legal and HR) define the adequate measures to be taken regarding the case.

Scene 10: Animation where the whistle-blower receives an email entitled Acknowledgment of receipt. You will be informed within a timeframe of max 3 months following the acknowledgment of receipt about the action envisaged or taken as follow-up to the report.

Scene 11: Animation where co-workers run after the whistle-blower. Proximus does not allow retaliation of any kind against those who, in good faith, report an infringement or suspicion of an infringement of the rules or guidelines.

Final slide: Link to the procedure on the Compliance section of the Proximus.com website - Compliance | Proximus Group.

Contact details for whistleblowing:

Email: whistleblower@proximus.com,  Hotline: 0800 45 002, Hotline if you call from outside Belgium: (+32 800 45 002)

Speak up! Help us protect the Proximus Group!