Whistleblower scheme

Qbuzz places great importance on integrity. We want to do business in an open and honest manner in accordance with laws, regulations, and internal Qbuzz policies.

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Introduction

Qbuzz attaches great importance to integrity. We want to conduct business in an open and honest manner in accordance with laws and regulations and internal Qbuzz policies. Nevertheless, something can go wrong within a company like Qbuzz. The employees of Qbuzz are the eyes and ears of our organisation and will often be the first to signal this. It is of great importance to Qbuzz that these signals reach those within Qbuzz who can do something about them.

It is very important that Qbuzz employees who, in good faith, wish to raise a possible misconduct or suspicion of misconduct of a general, operational or financial nature feel free to do so. This whistleblower scheme has been established for that purpose. By reporting a possible irregularity or misconduct in good faith, you enable Qbuzz to remedy any irregularities and learn from them for the future. In this way, you positively contribute to the image and achievement of Qbuzz’s objectives. Such a report will be taken seriously and will not affect your (legal) position. Qbuzz guarantees that you will not suffer disadvantages in your work and performance as a result of your report.

To conduct a proper investigation into a report, it is highly desirable that the report is not made anonymously. Anonymity can hinder the exchange of information in the context of the investigation and is also not necessary due to the protection Qbuzz offers to the notifier. Nevertheless, an anonymous report is possible under this scheme. Qbuzz prefers that a report is made anonymously rather than not at all.

The whistleblower scheme is not intended for individual complaints about undesirable conduct or about the personal employment situation. For such complaints, you can contact a confidential adviser. This whistleblower scheme is based on the standard regulations, as published by the Foundation of Labour.

This regulation is understood to mean:

The company: the private limited company Qbuzz B.V. and/or all its (subsidiary) companies. (Subsidiary) companies are all those entities in which Qbuzz B.V. has a direct or indirect interest of more than 50%;

The employee: everyone who is employed or has been employed for the benefit of the company, whether or not currently employed. This includes in any case employees of the company, temporary agency workers, self-employed persons, seconded staff, interns, and all others who work or have worked on a contractual basis for the company and/or represent or have represented the company, as well as other parties with whom the company does or has done business, such as contractors, advisors, and suppliers.

Supervisor: the person who directly supervises the employee and, in the absence of a direct supervisor, the general manager of Qbuzz B.V.;

Integrity Contact Point: the company's compliance officer;

The Whistleblower Committee: the committee established by the general manager of Qbuzz B.V. to act as such for the company; Qbuzz Whistleblower Regulation v0.2 – November 2017 2

Suspected misconduct: a reasonably grounded suspicion of irregularity within the company of an general, operational or financial nature, or the suspicion of an employee that there is misconduct where the public interest is at stake, but not exclusively:

a) a (threatening) criminal act;
b) a (threatening) violation of laws and regulations;
c) a (threat of) deliberately false or unlawful information, including to public authorities;
d) a (threatening) danger to the proper functioning of the organization due to improper conduct or negligence;
e) a (threatening) danger to safety;
f) a (threatening) danger to public health or the environment;
g) a (threat of) deliberately withholding, destroying, or manipulating information about these facts or other facts that could harm the company.

Article 2

Procedure

The employee reports a suspicion of wrongdoing internally to their supervisor or, if they do not consider reporting to their supervisor appropriate, to the Integrity Reporting Point. Reporting to the Integrity Reporting Point can also take place alongside reporting to their supervisor. Notwithstanding the above, reports to the Chairperson of the Board of Directors of Qbuzz are made in the cases specified in Article 3 paragraph 1.
The supervisor or the Integrity Reporting Point records the report, including the date on which it was received, in writing upon request and obtains the employee’s signature of approval on the record, of which a copy is provided to the employee. The supervisor or the Integrity Reporting Point ensures that the Chairperson of the Whistleblower Committee is promptly informed of a reported suspicion of wrongdoing and of the date the report was received, and that the Chairperson receives a copy of the record.
The Chairperson of the Whistleblower Committee sends an acknowledgment of receipt to the employee who has reported a suspicion of wrongdoing and indicates the timeline within which the investigation into the report is expected to be concluded.
Immediately after a suspicion of wrongdoing is reported, an investigation is initiated by the Whistleblower Committee.
The Whistleblower Committee handles the report confidentially to the extent that this is practically (due to the investigation to be carried out) and legally possible. No information is disclosed to third parties inside or outside the company without the approval of the Chairperson of the Whistleblower Committee.
The Whistleblower Committee keeps the employee who made the report informed about the progress of the investigation process in response to the report. When taking the report into consideration, the Committee discusses with the employee how they will be kept informed.
If the investigation cannot be completed within the specified timeframe, the employee is informed of this by or on behalf of the Chairperson of the Whistleblower Committee, and an indication is given of the period within which the investigation is expected to be completed.
The employee reporting the suspicion of wrongdoing and the person(s) to whom the suspicion has been reported treat the report and the investigation procedure confidentiality.

The employee may report a suspicion of a breach of conduct to the chairman of the Board of Directors of Qbuzz if:

he/she disagrees with the extension period for processing as referred to in article 2 paragraph 7;
the suspicion of a breach of conduct (also) concerns one of the statutory directors of the company;
the suspicion of a breach of conduct (also) concerns a member of the Whistleblower Committee;
there is a situation in which the employee, despite the legal protection offered under this regulation (see article 5), can reasonably fear retaliation as a result of a report under article 2;
a previous report has been made in accordance with the procedure in article 2 of essentially the same breach, and it has not been remedied;
there is an imminent danger, whereby a weighty and urgent social interest makes immediate external reporting necessary;
there is a legal obligation to report externally immediately.

The chairman of the Board of Directors of Qbuzz records the report, with the date on which it was received, in writing upon request and has that record signed for approval by the employee who receives a copy thereof.
The chairman of the Board of Directors of Qbuzz sends an acknowledgment of receipt to the employee and indicates the timeframe within which the investigation into the report is expected to be completed.
An investigation into the suspicion of a breach of conduct is initiated without delay following the report.
No information is provided to third parties within or outside the company without the approval of the chairman of the Board of Directors of Qbuzz.
The chairman of the Board of Directors of Qbuzz keeps the employee who made the report informed of the progress of the investigation procedure following the report. When handling the report, the chairman discusses with the employee how they will be kept informed.
If the investigation cannot be concluded within the specified timeframe, the employee is informed by or on behalf of the chairman of the Board of Directors of Qbuzz, and it is indicated within which period the conclusion of the investigation is expected.
The employee reporting the suspicion of a breach of conduct and the person(s) to whom the suspicion has been reported handle the report and the investigation procedure confidentially.

Article 4

Advisor

The employee can consult an advisor in confidence regarding a report or a possible report under this scheme.

Any person who enjoys the employee's trust and who, by virtue of their position, has a duty of confidentiality can serve as an advisor.

The employee who, in accordance with the provisions in this scheme, has reported a suspicion of a misconduct shall not be in any way disadvantaged in their position as a result of the report. Disadvantage shall in any case include taking a detrimental measure, such as imposing a disciplinary action, an appointment to a different position, or withholding promotion opportunities.
The employer ensures that managers and colleagues of the employee who has reported a suspicion of misconduct refrain from any form of disadvantage related to the report that hampers the professional and personal functioning of the reporter.
The employer reprimands employees who commit any form of discrimination against the employee who reported the suspicion of misconduct and may impose a warning or disciplinary action on them.
The employee of the company acting as an advisor, as referred to in Article 4 of this scheme, shall not be in any way disadvantaged due to holding that position. Entry into force Article 6 This scheme shall enter into force on 1 February 2018.

Whistleblower scheme

Introduction

Procedure

Advisor

Definitions

Notification to the Chairman of the Board of Directors of Qbuzz

Advisor

Procedure

Legal protection