C&A Foundation Whistleblowing Policy

 

Principle statement:


Violations of ethics and values as well as legal offences are taken very seriously by the foundation. Any stakeholder noticing a violation by another stakeholder can report it anonymously using this policy.
Why do we need this policy?
C&A Foundation considers it vital that its stakeholders understand and share C&A Foundation’s ethics and values. All stakeholders have responsibility to disclose any violations that may come to their attention, and thus help protect the organisation and the resources entrusted to them. This policy specifies when, how and to whom address concerns and complaints of violations of ethics within and from outside C&A Foundation.

Definitions:


Whistleblowing: the disclosure of information by an employee which relates to potential violations of internal financial, accounting and operational controls and procedures; misuse of resources; potential violations of applicable laws and regulations, including fraud against the organisation. 
Whistleblower: an individual who reports a suspicion of a violation of C&A Foundation rules (“Suspected Violation”). Whistleblowers provide information, based on a reasonably held suspicion that a wrongdoing has occurred. 
Retaliation: any direct or indirect adverse action that is threatened, recommended or taken against an employee because he or she reported a suspicion of wrongdoing.

 

Key principles of the policy: 


Any C&A Foundation stakeholder noticing a suspicious behaviour or act against  C&A Foundation’s ethics by another stakeholder should try to discuss the matter directly with that stakeholder, to understand the reason for that behaviour or act. 
If talking to the suspicious stakeholder is not possible or if there is a threat of retaliation, the matter should be reported to the line manager of the suspicious stakeholder or immediate superior of the reporting stakeholder, who in turn can report it further.
If none of the above is possible, or if the reporting person does not have contact details of any of the above, the matter can be directly reported to whistleblower@candafoundation.org.
Violations should be ideally reported in writing as soon as possible and normally not later than 6 months after the event(s) has occurred. The report should be factual and must contain as much specific information as possible to allow for a proper assessment of the nature, extent and urgency of the matter. 
Anyone reporting a suspected or actual violation must be acting in good faith and must have reasonable grounds for believing the information disclosed constitutes a potential violation.
When reporting a suspected violation in good faith, the reporting person shall be protected from retaliation by the management.
Reports of suspected violations will be kept confidential to the maximum extent possible, consistent with the need to conduct a proper investigation. The identity of the whistleblower will also be kept confidential (subject only to any legal requirements).
A formal investigation report of all whistleblowr incidents will be submitted to the Executive Director of C&A Foundation, unless the report was against the Executive Director, in which case it will be reported to the Board of Foundation.
 

 

Contact for questions or exceptions:


If you would like to report an incident or (suspected) breach of ethics, you can report it anonymously at whistleblower@ candafoundation.org