Whistleblower policy

1. Purpose - Why?

Our corporate values and behavioral guidelines are detailed in the Gighouse Code of Conduct & Ethics
Through our Code of Conduct & Ethics, we aim to instill corporate values and principles in our professional and
outline personal behavior and commit to fulfilling our mission in an ethical manner.
This procedure provides additional regulation of our vision and principles under
whistleblowing, as described in the Code of Conduct & Ethics. It provides a framework for internal
reporting and for following up on suspected misconduct. We believe that everyone
can and should raise awareness if he/she believes in good faith that unethical practices or
misconduct is going on.
This regulation was also adopted to implement Directive (EU) 2019/1937 on the
protection of persons reporting violations of Union law as well as Belgian
legislation that transposed the Directive into national law. The overall goal of the European
Directive and Belgian law is to protect whistleblowers from retaliation in any form
and require public and private organizations to establish formal procedures for internal reporting
and follow-up on reports.
We emphasize that everyone has the responsibility for contributing to and maintaining
a culture of transparency and openness, free from retaliation. More specifically, it bears
management of Gighouse an important responsibility to act in
consistent with our core values and policies. They should not only lead by example
give, but also support their team members in their efforts to uphold these principles.

2. Scope - Who?

In accordance with the European directive and Belgian legislation, the Whistleblower Policy is
of Gighouse apply not only to current and future employees, but also to
former employees, self-employed persons, shareholders and persons belonging to the
administrative, managerial or supervisory body, volunteers and paid or unpaid interns,
applicants, all persons working under the supervision and direction of contractors, subcontractors and
Consequently, the internal reporting channels described in these regulations will be opened to all
aforementioned parties, all of whom will be protected from retaliation by Gighouse.

3. Misconduct - What?

This Whistleblower Policy applies to all suspected or actual (attempts to)
unlawful, unethical or non-legitimate conduct relating to Gighouse (hereinafter the "reportable
For the purposes of this scheme, a distinction is made between the following types
reportable violations:
1) Infringements falling within the scope of the European Directive and Belgian law
fall, namely violations relating to:
- Public contracts;
- Financial services, products and markets and prevention of money laundering and financing
of terrorism;
- Product safety and compliance;
- Transportation safety;
- Environmental protection;
- Infringements affecting the financial interests of the Union and/or related to
the single market;
- Food and feed safety, animal health and welfare;
- Public Health;
- Consumer protection;
- Protection of privacy and personal data, and security of network and
information systems;
- Social fraud;
- Fiscal fraud;
- Radiation protection and nuclear safety;
Gighouse's Whistleblower Policy applies not only to workplace violations,
in public and private places, but extends to violations involving all work-related activities such as (non-exhaustive):
- During conferences, seminars or trainings
- During work-related travel
- During events after work
- Through work-related communication
- In accommodation provided by the employer, such as at the
Providing residential facilities to people at work
Gighouse stresses and undertakes to all persons who in good faith suspect or
report actual (attempted) violations, protect against retaliation.

4. Blow the whistle! - How to.

Breaches of Union law should be detected, addressed at an early stage and
remedied. Providing channels for reporting violations or misconduct ("whistleblowing") is
This Whistleblower Policy is intended to provide internal channels for reporting
Observations or findings regarding (suspected) violations involving
Gighouse , without having to follow the hierarchical route or the usual channel. It is not a
replace but complement existing procedures for handling (individual)
complaints or irregularities. Whistleblower channels have been established to report (attempts at) illegal, unethical or non-legitimate behavior when not through the usual channels, such as the
immediate supervisor, the HR manager or other regular designee, may be
We encourage all employees of Gighouse , former employees, self-employed,
shareholders, persons serving on the board of directors, management or supervisory
body, volunteers and interns, applicants for employment, all persons under the supervision and direction of
work contractors, subcontractors and suppliers, to any form of suspected or
report actual violations or misconduct through the dedicated internal channels that Gighouse has
implemented. We take all reports received seriously and are committed to making every report
You can report in several ways:
If possible, discuss the issue with your reporting manager in person, by phone or email

Melissa Goossens
HR Legal Expert
+ 32 470 99 25 18

Joke Vancoppernolle
Company Lawyer
+ 32 496 71 35 52

If you feel unable to do so, you can report the misconduct through our reporting tool (SPOT):
Spot allows you to report actual or suspected misconduct in an accessible and, if desired, anonymous way.
way to raise concerns. The customized workflow within Spot guides whistleblowers through the entire process.
Each issue is handled and followed up according to existing escalation procedures. Open the tool
via talktospot.com/hohr or via the QR code.
Although Gighouse hopes that reporting a concern through the internal reporting channels will provide sufficient relief
offers and is therefore preferred, there may be circumstances in which it is more appropriate to use a
concerns directly to an outside agency. If applicable, you may report your
report concerns directly to the Federal Ombudsman .

5. Treatment and research

For each report, you will receive an acknowledgement of receipt within seven calendar days. The
reporting manager will also inform you whether the report is assessed as potential misconduct,
or whether it is a matter to be handled through normal notification procedures. If this
is deemed necessary, the reporting manager together with whistleblower committee (composed of: company lawyer, HR Legal Expert, Audit manager and the operations manager) will conduct an investigation
Set to the content of the notification.
During the investigation, the reporting administrator may also contact you (via SPOT or, if
possible, directly) for further clarification. As required by the European Directive, Gighouse must
the right of persons named in the report to be heard and the right of access to
respect their file, taking into account the anonymity and confidentiality of the
report and the reporter and without jeopardizing the investigation.
Within three months of the acknowledgement of receipt, the reporting manager will, to the extent possible and with
consideration of any applicable confidentiality requirements or privacy issues with
with respect to anyone who is the subject of the report, report to the reporter on the
status of the investigation and any mitigation measures taken.
All reports are kept confidential and information is shared only on a "need to
know" basis. Records of each report will not be kept longer than necessary and appropriate to
meet the requirements of the Directive.
All personal data collected by Gighouse under this Whistleblower Policy is
processed are carried out in accordance with applicable law and are only
used to achieve the objectives of this scheme.

6. Non-retaliation

The identity of the reporter and any other information that directly or indirectly reveals the identity of the reporter
can be derived, shall be kept confidential to the extent possible. This information may only
disclosed when in connection with investigations by national authorities or
legal proceedings is a necessary and proportionate obligation imposed by Union law
or national law is imposed. If information is made public, the reporter will be
so notified before his identity is disclosed, unless that information makes the
relevant investigation or court proceedings would be jeopardized.
The reporter acting in good faith and on reasonable grounds ("legitimate reasons"/"motifs
raisonnables") is protected from retaliation by this Whistleblower Policy. There are no
repercussions associated with reporting in good faith and on reasonable grounds a (potential)
violation, even if the report is subsequently found to be unfounded. This means that the reporter is not subject to any
should in any way be disadvantaged as a result of his or her report.
If the reporter demonstrates that he or she is being punished, unfairly
is treated or otherwise disadvantaged, it is presumed that the injury is
inflicted in retaliation for the report, unless the person who took the adverse action
taken can show that that action was based on legitimate reasons and no
was related to the reporter's reporting act. If the investigation reveals that a report is false
or made in bad faith, this may be grounds for appropriate and reasonable action against the reporter
take. Any person who violates the provisions of these regulations may be subject to disciplinary
measures are taken, including dismissal.