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
Internal Reporting: Concerns can be raised confidentially to:
The Designated Whistleblower Officer (e.g., Compliance Lead or Board chair), at [email protected].
Alternative Internal Option: If uncomfortable reporting to the above, individuals may contact another senior officer or board member.
External Reporting: For breaches of EU law, individuals may report to relevant national authorities as permitted by Directive 2019/1937.
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.
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