Whistleblowing policy


  1. Purpose – Why?

Our corporate values ​​and behavioral guidelines are detailed in Logi-technic’s Code of Ethics and Business Conduct. Our Code of Ethics and Business Conduct sets out the company’s values ​​and principles in our professional and personal conduct and commits us to fulfilling our mission in an ethical manner.

This procedure provides an additional arrangement to our whistleblowing vision and principles, as described in the Code of Ethics and Business Conduct. It provides a framework for internal reporting and for following up on suspected misconduct. We believe that anyone can and should raise awareness if they believe in good faith that unethical practices or misconduct are occurring.

This scheme was also adopted in implementation of Directive (EU) 2019/1937 on the protection of persons reporting infringements of Union law, as well as the Belgian legislation transposing the Directive into national law. The general purpose of the European directive and Belgian law is to protect whistleblowers against retaliation in any form and to oblige public and private organizations to establish formal procedures for internal reporting and follow-up of reports.

We emphasize that everyone has a responsibility to contribute to and maintain a culture of transparency and openness, free from retaliation. More specifically, Logi-technic’s management has an important responsibility to act in accordance with our core values ​​and policies. They must not only lead by example, but also support their team members in their efforts to uphold these principles.

  1. Scope – Who?

In accordance with the European directive and Belgian law, the Logi-technic  Whistleblower Policy applies not only to current employees, but also to former employees, self-employed persons, shareholders and persons who are part of the administrative, management or supervisory body, volunteers and paid or unpaid interns, job applicants, all persons working under the supervision and direction of contractors, subcontractors and suppliers.

Accordingly, the internal reporting channels described in this arrangement will be opened to all aforementioned parties, all of whom will be protected by Logi-technic  against retaliation. In the context of this Whistleblower Policy, Logi-technic  refers to Logi-technic nv, Logi-technic Building nv, Logi-technic Infra nv.

  1. Misconduct – What?

This Whistleblower Policy applies to all suspected or actual (attempted) unlawful, unethical or illegitimate conduct relating to Logi-technic (hereinafter the “reportable violations”).

In the context of this scheme, a distinction is made between the following types of reportable infringements :

  • Infringements that fall within the scope of the European Directive and Belgian law, namely infringements relating to:
  • Government procurement
  • Financial services, products and markets and prevention of money laundering and terrorist financing
  • Product safety and compliance
  • Transport safety
  • Environmental protection
  • Infringements affecting the financial interests of the Union and related to the internal market
  • Food and feed safety, animal health and welfare
  • Radiation protection and nuclear safety
  • Public health
  • Consumer protection
  • Protection of privacy and personal data, and security of network and information systems
  • Social fraud
  • Tax fraud
  • Infringements that do not directly fall within the scope of the European Directive and Belgian law, but which may nevertheless constitute suspected or actual (attempted) unlawful, unethical or illegitimate behavior. Examples of such violations are (non-exhaustive):
  • Violations of human rights principles
  • Violations of business principles or practices that conflict with the values ​​of our Code of Ethics and Business Conduct
  • Violations of Logi-technic policies or procedures
  • Criminal offenses (e.g. anti-competitive practices, discrimination, intimidation, bribery, fraud)
  • Non-compliance with obligations imposed by law or regulation (including improper financial and accounting practices)

Logi-technic’s Whistleblowing Policy applies not only to breaches in the workplace, in public and private spaces, but extends to breaches relating to all work-related activities such as (non-exhaustive):

  • During conferences, seminars or training courses
  • During work-related travel
  • During after-work events
  • Through work-related communication
  • In accommodation made available by the employer, for example when providing living facilities to people at work

Logi-technic emphasizes and undertakes to protect against retaliation all persons who in good faith report suspected or actual (attempted) infringements.

  1. Blow the whistle! – How?

Infringements of Union law or other forms of misconduct must be detected, addressed and remedied at an early stage. Providing channels for reporting breaches or misconduct (“whistleblowing”) is essential.

This Whistleblowing Policy is intended to provide internal channels for reporting observations or findings regarding (suspected) infringements relating to Logi-technic, without having to follow the hierarchical route or the usual channel. It is not a replacement but a supplement to the existing procedures for handling (individual) complaints or irregularities. Whistleblowing channels have been established to report (attempted) illegal, unethical or illegitimate behavior when this cannot be reported through the usual channels, such as the direct supervisor, the HR manager or another regular designated person.

We encourage all Logi-technic employees, former employees, self-employed persons, shareholders, persons who are part of the administrative, management or supervisory body, volunteers and trainees, job applicants, all persons who work under the supervision and direction of contractors, subcontractors and suppliers, to report any form of suspected or actual infringements or misconduct through the special internal channels that Logi-technic has implemented. We take all reports received seriously and are committed to investigating every report.

You can report in different ways:

  • If possible, discuss the matter with your DPO in person, by telephone or by email:

DPO Logi technic:

Chris De Bruyne


  • If you feel unable to do so, you can report the misconduct via our reporting tool (SPOT): https://app.talktospot.com

Spot allows you to raise actual or suspected misconduct in an accessible and, if desired, anonymous manner. The customized workflow within Spot guides whistleblowers through the entire process. Each issue is handled and followed up according to existing escalation procedures.

Although Logi-technic hopes that reporting a concern through the internal reporting channels will provide sufficient relief and is therefore preferable, there may be circumstances where it is more appropriate to report a concern directly to an external agency. If applicable, you can report your concerns directly to the Federal Ombudsman and the Federal Institute for the Protection and Promotion of Human Rights (FIRM-IFDH).

  1. Treatment and examination

You will receive confirmation of receipt for each notification within seven calendar days. The DPO will also inform you whether the report is assessed as potential misconduct, or whether it is a matter that should be dealt with through normal reporting procedures. If this is deemed necessary, the DPO will conduct an investigation into the content of the report.

During the investigation, the DPO may also contact you (via SPOT or, if possible, directly) for further clarification. As required by the European Directive, Logi-technic must respect the right of the persons mentioned in the report to be heard and the right of access to their file, taking into account the anonymity and confidentiality of the report and the reporter and without jeopardize research.

Within three months of the acknowledgment of receipt, the DPO or the designated Whistleblowing Officer will, to the extent possible and taking into account any applicable confidentiality requirements or privacy issues relating to anyone who is the subject of the report, report to the reporter on the status of the investigation and any mitigating measures taken.

All reports are treated confidentially and information is only shared on a ‘need to know’ basis. The data of each report will not be kept longer than is necessary and appropriate to meet the requirements of the Directive.

All personal data processed by Logi-technic in the context of this Whistleblowing Policy will be processed in accordance with applicable legislation and will only be used to achieve the objectives of this policy. 

  1. Non-retaliation

The identity of the reporter and all other information from which the identity of the reporter can be directly or indirectly derived are kept confidential as much as possible. This information may only be disclosed where this is a necessary and proportionate obligation imposed by Union or national law in the context of investigations by national authorities or judicial proceedings. If information is made public, the reporter will be informed before his identity is revealed, unless that information would jeopardize the relevant investigation or legal proceedings.

A reporter who acts in good faith and on reasonable grounds ( “legitimate reasons”/”motives raisonnables” ) is protected against retaliation by this Whistleblowing Policy. There are no repercussions associated with reporting a (possible) infringement in good faith and on reasonable grounds, even if the report subsequently turns out to be unfounded. This means that the reporter may not be disadvantaged in any way as a result of his or her report.

If the reporter demonstrates that he or she is being punished, treated unfairly or otherwise disadvantaged as a result of his or her report, the damage is presumed to have been inflicted in retaliation for the report, unless the person who took the negative measure taken can demonstrate that that measure was based on justified reasons and was not in any way related to the reporting act of the reporter. If the investigation shows that a report was made falsely or in bad faith, this may be reason to take appropriate and reasonable measures against the reporter. Disciplinary measures, including dismissal, may be taken against anyone who violates the provisions of these regulations.