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Whistleblowers and JEX

Last modified: November 2023

JEX believes it is important that you can report a (suspected) wrongdoing in a safe manner, without having to fear negative consequences.

Based on the Whistleblower Protection Act, we have established a reporting procedure, which we hereby provide to you. This procedure enables you to report misconduct at an early stage, allowing us to respond quickly and effectively. JEX stands for an open culture, in which integrity and holding each other accountable for behavior are encouraged and appreciated.

The JEX Works Council is familiar with this arrangement and approved it on November 1, 2023.

 

  1. What the reporting procedure is intended for

This procedure is intended for reporting (suspected) misconduct that is in the public interest. The reporting procedure is not intended for (individual) labor disputes, reporting personal complaints about work, expressing criticism of the (policy) choices made by JEX, and/or for personal gain. There must therefore be a broader interest at stake. 

  1. What is meant by this?

The reporting procedure concerns:

    1. you: the person who performs work for us (whether or not as an employee), including on behalf of another company (client). This includes our own staff, interns, volunteers, and temporary workers;
    2. we/us or JEX: JEX Backoffice B.V., JEX Personeel B.V., and other entities belonging to our group that allow you to perform work (whether or not as an employee), including for the benefit of other companies (clients);
    3. (presumed) misconduct: your reasonable suspicion that there is a wrongdoing that jeopardizes the public interest. This is the case when:
      • a violation of the law;
      • (risk of) a breach of Union law;
      • a threat to public health;
      • a safety hazard;
      • a danger to the environment;
      • a violation of JEX's internal rules;
      • a threat to the proper functioning of our organization or a public service through improper conduct or omission;
    4. whistleblower advisor: the person who acts as our confidential advisor and whom you can consult about a (suspected) wrongdoing. JEX's whistleblower advisor is Rosalie Knoppert;
    5. Chief Executive Officer: the person who is responsible for the day-to-day management of our company, Nick Hillebrand.

 

  1. About the internal report

You can report a (suspected) wrongdoing to the whistleblower advisor. You can also consult the whistleblower advisor in confidence about a (suspected) wrongdoing by requesting information or advice. If you suspect that the whistleblower advisor is involved in the (suspected) wrongdoing, the report can also be made to his or her immediate supervisor within JEX.

You can report a (suspected) wrongdoing in the following way:

  1. in writing (including via email or WhatsApp);
  2. verbally via telephone or other voice messaging systems;
  3. or at your request via an on-site meeting within a reasonable period of time.

You will receive confirmation of receipt of the report within seven days.

If a (suspected) wrongdoing relates to a company other than JEX (such as a client), you can report it to that other company. In that case, JEX's whistleblower advisor will be informed by that other company that a report has been made.

During the investigation, you and other parties involved may be interviewed. You will be given the opportunity to comment on the draft investigation report, unless there are serious objections to this. We aim to deliver the investigation report within eight weeks of the report being filed. We will inform you in writing of our position on the report. We will also indicate what (follow-up) steps the report has led to or will lead to.

  1. About the external report

You can immediately report a (suspected) wrongdoing externally to the Whistleblowers Authority or to any other competent authority designated by law. For more information, see: www.wetbeschermingklokkenluiders.nl. You can also do this after an internal report. It is preferable to make an internal report first.

  1. How we protect you from harm

We ensure that the information about your report is stored in such a way that it is physically and digitally accessible only to those involved in handling this report. We process all data confidentially and—to the extent permitted—in accordance with the General Data Protection Regulation and other relevant legislation.

We also ensure that your identity is not disclosed to those involved in handling a report. An exception to this is if you give your express written consent and they treat your identity confidentially.

You are acting in good faith and reporting a (suspected) wrongdoing in accordance with this policy. JEX will not disadvantage you in any way in connection with the report. We will also ensure that your colleagues refrain from any form of disadvantage that hinders your professional or personal functioning. If you do experience any disadvantage, you can discuss this with the whistleblower advisor. They will inform your immediate supervisor (or the immediate supervisor at the client) about this.

Other parties involved, including, for example, the confidential advisor and/or the investigators, will not be disadvantaged in any way by us in connection with the report.