Whistleblower Contact

  1. Purpose

BGN ( “we”, “us”, “our” or “the Company”) is committed to the highest standards of integrity, ethical conduct, and compliance with “Applicable Laws” which means all relevant laws and regulations, including but not limited to GDPR, UK GDPR, and other regulations.

This Whistleblower Policy establishes a framework for the confidential reporting, handling, and investigation of concerns related to misconduct or violations, while ensuring protection against retaliation for individuals who report concerns in good faith.

 

  1. Scope of Application

This policy applies to reports made by:

  • Employees (current and former)
  • Job applicants
  • Contractors, consultants, and temporary workers
  • Suppliers and business partners
  • Other external stakeholders who obtain information in a workrelated context

This policy applies globally, subject to applicable local laws.

 

  1. Reportable Concerns

Concerns that may be reported under this policy include, but are not limited to:

  • Violations of laws or regulations
  • Fraud, corruption, or bribery
  • Financial misconduct or accounting irregularities
  • Breaches of data protection or information security requirements
  • Violations of company policies or codes of conduct
  • Serious health, safety, or environmental risks
  • Attempts to conceal any of the above

Personal employment grievances that do not involve misconduct should generally be addressed through standard HR procedures.

 

  1. Reporting Channels

BGN provides a confidential whistleblower channel for submitting reports. Reports may be made in writing, via info@bgn-int.nl

Where permitted by law, reports may be submitted anonymously.

 

  1. Confidentiality and Data Protection

BGN treats all whistleblower reports with strict confidentiality. The identity of the reporting person and any third parties mentioned in a report will be protected and disclosed only to authoriszed personnel who have a legitimate need to know, or where required by law.

Personal data collected under this policy will be processed in accordance with applicable data protection laws and BGN’s Privacy Policy. For more information, please refer to our Privacy Policy.



  1. NonRetaliation

BGN strictly prohibits any form of retaliation against individuals who raise concerns in good faith, even if the reported concern is ultimately not substantiated.

Retaliation may include dismissal, demotion, discrimination, harassment, or any other adverse treatment. Any act of retaliation may result in disciplinary action, up to and including termination of employment or contractual relationships.

Concerns regarding retaliation may themselves be reported through the whistleblower channel.

 

  1. Handling of Reports

All reports are:

  • Acknowledged within a reasonable timeframe, where contact details are available
  • Assessed objectively and independently
  • Investigated in a fair, impartial, and confidential manner

BGN will take appropriate corrective or remedial action where misconduct is identified. Where legally permissible, feedback will be provided to the reporting person on the outcome or progress of the investigation.

 

  1. External Reporting

Nothing in this policy prevents individuals from reporting concerns directly to competent authorities, regulators, or law enforcement bodies, in accordance with applicable laws.

 

  1. Misuse of the Whistleblower Channel

This policy is intended to encourage responsible reporting. Reports made knowingly false or in bad faith may result in disciplinary or other appropriate action. However, no action will be taken against individuals who make reports in good faith based on reasonable belief.

 

  1. Policy Review and Updates

BGN reserves the right to amend this Whistleblower Policy at any time to reflect changes in legal requirements or business practices. The current version will always be available on BGN’s website.

 

  1. Contact Information

For questions regarding this policy or the whistleblower process, please contact:

info@bgn-int.nl