1. Purpose
This policy establishes a clear and safe mechanism for individuals to raise concerns about potential wrongdoing within or related to Hybrid Core BV. It reflects the company's commitment to transparency, accountability, and legal compliance, including under the EU Whistleblower Directive (2019/1937) and its transposition into Belgian law.
2. Scope
This policy applies to all employees, directors, contractors, trainees, volunteers, and former employees of Hybrid Core BV. It also applies to individuals who have acquired information about the company's activities in the context of a work-related relationship, including suppliers and business partners.
3. Policy statement
Hybrid Core BV encourages the reporting of genuine concerns about wrongdoing and is committed to protecting those who raise concerns in good faith. All reports will be taken seriously, investigated appropriately, and treated with confidentiality to the extent possible.
The company will not tolerate retaliation of any kind against a person who makes a protected disclosure. Retaliation, including demotion, dismissal, disciplinary action, or other adverse treatment, constitutes a serious disciplinary offence.
4. What can be reported
A concern may be raised about any suspected, actual, or likely wrongdoing, including:
- Criminal offences, including fraud, bribery, or theft
- Violations of legal or regulatory obligations
- Dangers to health, safety, or the environment
- Misuse of public funds, including in EU-funded projects
- Breaches of data protection or information security obligations
- Deliberate concealment of any of the above
- Serious breaches of the company's own policies and standards
This policy is not intended as a route for raising personal grievances, which should be addressed through the company's grievance procedure.
5. Principles
5.1 Confidentiality
The identity of anyone raising a concern will be kept confidential to the extent possible and consistent with conducting a fair investigation. Hybrid Core BV will not disclose the identity of a reporting person without their consent, unless required by law or where disclosure is strictly necessary for the investigation.
5.2 Anonymous reporting
Anonymous reports will be accepted and considered. However, the ability to investigate and follow up may be limited where no contact details are provided.
5.3 Good faith reporting
This policy protects individuals who raise concerns honestly and reasonably, even if those concerns turn out to be unfounded following investigation. Protection is not available to individuals who make deliberately false or malicious allegations.
5.4 Protection from retaliation
Any employee who retaliates against a reporting person will face disciplinary action. Where retaliation is identified, the company will take steps to remedy any adverse consequences suffered by the reporting individual.
6. Reporting channels
Concerns may be raised using any of the following channels:
- Directly to a line manager or member of the management team
- By email to the designated contact: management@hybridcore.eu
- Through an external reporting channel as provided under applicable Belgian law
Where a concern relates to the conduct of a member of the management team, the reporting person should use an alternative channel or escalate directly to the Board.
7. Investigation process
All reports will be acknowledged within seven days of receipt. An initial assessment will be conducted to determine the nature and seriousness of the concern. Where an investigation is warranted, it will be conducted objectively, with due care for both the reporting person and anyone implicated. The reporting person will be informed of the outcome to the extent possible and consistent with confidentiality.
8. Responsibilities
The management team is responsible for ensuring this policy is communicated effectively, that reports are handled fairly and promptly, and that appropriate records are maintained. All employees are responsible for cooperating with any investigation and for not taking any action that constitutes retaliation.
9. Reporting and compliance
Where a concern relates to possible fraud affecting EU-funded activities, the company may be required to report the matter to the European Anti-Fraud Office (OLAF). Individuals may also have the right to report concerns to competent national or European authorities directly under applicable law.
10. Monitoring and review
The effectiveness of this policy and its reporting mechanisms will be reviewed annually. The number and nature of concerns raised will be monitored in aggregate to identify any systemic issues requiring management attention.
11. Communication and awareness
This policy is communicated to all employees at induction and is published on the company's internal systems. Employees are encouraged to read it carefully and to ask questions if anything is unclear.
12. Review cycle
This policy is reviewed every two years, or sooner following material legislative changes or after any significant whistleblowing incident.
13. Version control
Version: 1.0
Owner: Hybrid Core Management Team
Approved by: Hybrid Core Management
Effective Date: 01.06.2026
Review Period: Every 2 Years