Whistleblower Policy

This page explains how you can report breaches safely and confidentially under the Belgian Whistleblower Act.
We encourage using the internal reporting channel first.


Internal reporting
Email: whistleblower@dpsurveys.be
Confidential
Access is limited to designated reporting managers.
Protection
No retaliation against reporters acting in good faith.
Internal reporting External reporting

1. General

The purpose of this Whistleblower Policy is to enable both internal employees and external parties to report, without fear of reprisal, breaches falling within the material scope of the Belgian Whistleblower Act, of which they have become aware in a work-related context.

To facilitate such reports, DP Survey Group has established an internal reporting channel. Anyone wishing to make a report within the scope of the Whistleblower Act is encouraged to use this internal reporting channel in the first instance.

2. Definitions

Infringements
Acts or omissions that:

  • are unlawful and relate to the policy areas covered by the material scope of Chapter 4;
  • go against the purpose or application of the rules in the policy areas covered by the material scope of Chapter 4.

Breach information
Information, including reasonable suspicions, about actual or potential breaches that have occurred or are highly likely to occur within DP Survey Group, as well as attempts to conceal such breaches.

Reporting
The oral or written communication of information about breaches.

Internal reporting
The oral or written communication of information about breaches within a legal entity in the private sector.

External reporting
The oral or written communication of information about breaches to the federal coordinator or competent authorities.

Disclosure
Making information about breaches publicly available.

Reporter
A person who reports or discloses information about breaches.

Work-related context
Current or former professional activities through which individuals may obtain information about breaches and where they may face retaliation if they report such information.

Facilitator
A natural person who assists a reporter in the reporting process and whose assistance must remain confidential.

Subject
A natural or legal person named in a report or disclosure as the person to whom the breach is attributed or with whom that person is associated.

Retaliation
Any direct or indirect act or omission in response to a report or disclosure that causes or may cause unjustified harm to the reporter.

Follow-up
Actions taken to assess the accuracy of allegations and address the reported breach.

Feedback
Information provided to the reporter on follow-up actions taken or planned and the reasons for those actions.

Competent authority
The Belgian authority designated to receive external reports and ensure follow-up.

Federal coordinator
The authority responsible for coordinating external reports for the private sector.

Reporting manager
The impartial person or department responsible for managing reports, communicating with reporters, and ensuring follow-up.

3. Who Can Report?

  • Employees
  • Former employees
  • Trainees
  • Self-employed persons
  • Suppliers and subcontractors
  • Shareholders
  • Job applicants
  • Individuals in long-term cooperation with DP Survey Group
  • Customers and other stakeholders

4. Scope of Reports

  • Government procurement
  • Financial services, products and markets
  • Prevention of money laundering and terrorist financing
  • Product safety and compliance
  • Transport safety
  • Environmental protection
  • Radiation protection and nuclear safety
  • Food and feed safety, animal health and welfare
  • Public health
  • Consumer protection
  • Privacy and personal data protection
  • Network and information systems security
  • Financial interests of the European Union
  • Internal market infringements
  • Tax fraud
  • Social fraud

5. Internal Reporting

5.1 Reporting Channel

Reports can be submitted at any time via email to:
📧 whistleblower@dpsurveys.be

A physical meeting may also be requested within a reasonable time by contacting the same email address.

5.2 Procedure

The internal reporting channel is managed internally by DP Survey Group.
The designated reporting managers are:

  • Rinda Smekens
  • Bert Delbaere

An acknowledgement of receipt will be sent within seven days of receiving a report.
Conflicts of interest are avoided at all times. Where necessary, external investigators may be appointed.

5.3 Feedback

Reporters will receive feedback on follow-up actions within three months of acknowledgment of receipt.
Feedback will be general in nature and will not disclose personal data or confidential investigation details.
If feedback cannot be provided, the reporter will be informed accordingly.

6. External Reporting

6.1 External Channels

  • Telephone: 0800 999 61
  • Email: integriteit@federaalombudsman.be
  • Website: Federaal Ombudsman
  • Report form: Available on the Federaal Ombudsman website

Reports may also be made in person by appointment.

6.2 Procedure

Acknowledgment of receipt will be provided within seven days.
Feedback will be provided within three months (exceptionally six months).
All handling staff are bound by strict confidentiality obligations.

7. Disclosure

Public disclosure is protected if:

  • No appropriate action was taken following an internal or external report; or
  • There is an imminent risk to the public interest or a high risk of retaliation.

This does not apply to direct disclosures to the press unless covered by specific legislation.

8. Confidentiality & Data Protection

8.1 Confidentiality

  • Access to reports is strictly limited to designated reporting managers
  • Reporter identities are never disclosed without explicit consent
  • Information is shared strictly on a need-to-know basis

8.2 Personal Data Processing

Personal data is processed in compliance with GDPR.
Requests regarding personal data may be sent to:
📧 whistleblower@dpsurveys.be

Complaints may be lodged with the Belgian Data Protection Authority.

8.3 Record Keeping

Reports are registered and stored securely. Investigation records are retained for a minimum of five years after closure.

9. Protection Against Retaliation

DP Survey Group strictly prohibits retaliation against reporters acting in good faith.

Protected persons include:

  • Reporters
  • Facilitators
  • Associated third parties

Retaliation includes dismissal, demotion, harassment, discrimination, reputational damage, contract termination, and similar actions.

10. Abuse of Reporting

Only reports made in good faith are protected. Malicious or knowingly false reports may result in disciplinary action, including dismissal.

Appendix I - Competent Authorities

A full list of Belgian federal authorities authorised to receive and investigate reports is available, including (but not limited to):

  • FPS Economy
  • FPS Finance
  • FPS Health
  • FPS Mobility
  • FPS Employment
  • Belgian Competition Authority
  • Data Protection Authority
  • National Bank of Belgium
  • Financial Services and Markets Authority
  • Shipping Inspectorate