Whistleblower Policy

1. Purpose

OCE commits to the highest standards of integrity and transparency. This Whistleblower Policy enables individuals to report misconduct such as illegal or unethical behavior—including financial mismanagement, fraud, harassment, discrimination, or violation of OCE's policies—without fear of retaliation.

2. Scope

Applies to all board members, staff, volunteers, fiscal hosts, partners, contractors, and anyone engaged in OCE-related activities, including those reporting on behalf of them.

3. What Should Be Reported

Suspected breaches such as:

• Violations of EU or Belgian law

• Financial misconduct (e.g., misuse of funds, fraudulent reporting)

• Ethical violations (e.g., harassment, discrimination, safeguarding breaches)

• Violations of OCE policies or governance standards

4. Reporting Channels

1. Internal Reporting: Concerns can be raised confidentially to:

2. The Designated Whistleblower Officer (e.g., Compliance Lead or Board chair), at [e-mail].

3. Alternative Internal Option: If uncomfortable reporting to the above, individuals may contact another senior officer or board member.

4. External Reporting: For breaches of EU law, individuals may report to relevant national authorities as permitted by Directive 2019/1937.

5. Public Disclosure: Only if internal and external reporting channels are exhausted or if there is an imminent threat to the public interest, as allowed by the Directive.

5. Confidentiality

Reports will be handled discreetly. Identities of whistleblowers and details of the report will be kept confidential unless disclosure is legally required.

6. Protection Against Retaliation

OCE prohibits retaliation. Any adverse action—such as dismissal, demotion, discrimination, or threats—against a good-faith reporter is strictly forbidden. Violations may result in disciplinary measures, including removal.

7. Investigation Process

• Acknowledge receipt within a set timeframe (e.g., 7 days).

• Investigate promptly and fairly.

• Maintain confidentiality.

• Document outcomes and corrective actions.

8. Good Faith Requirement

Reports must be made in good faith—believing the information is true at the time of disclosure. Malicious or knowingly false claims may result in consequences.

9. Policy Awareness and Distribution

The policy will be:

• Published on OCE’s website and internal documentation.

• Shared with board members, staff, and volunteers.

• Included in onboarding materials and reviewed regularly.

10. Annual Review

The policy will be reviewed annually or as legal requirements evolve, to ensure ongoing compliance and effectiveness.