On December 24 and 31, our offices will exceptionally close at 4 PM. Happy holiday season!
On December 24 and 31, our offices will exceptionally close at 4 PM. Happy holiday season!
The reporting system allows you to quickly and easily report concerns about actual or suspected misconduct that could affect our business or the well-being of people.
The reporting system should not be used to falsely accuse others and/or intentionally provide false information. We encourage you to include your name and contact information in the report, but if you prefer, you may remain anonymous. All reports are strictly confidential and are handled exclusively by a dedicated unit. More information can be found in the “Privacy Policy” and “Whistleblower Policy” sections.
1. public procurement violations
2. violations related to financial services, products and markets (including prevention of money laundering and terrorist financing)
3. violations affecting product safety and regulatory compliance
4. violations affecting the safety and security of all means of transportation
5. violations affecting the protection of the environment
6. violations affecting nuclear safety or protection from harmful radiation
7. violations affecting food and feed safety and animal health and welfare
8. violations affecting public health
9. violations affecting consumer protection.
10. breaches affecting the protection of privacy and personal data, and the security of network and information systems
11. violations related to the fight against tax fraud
12. violations related to combating social security fraud
Using this tool, you can provide information and communicate with case investigators while remaining anonymous. To ensure your anonymity, you must adhere to the following principles:
Keep in mind that when you make a whistleblower report, your identity is always protected, even if you choose not to report anonymously.
Policy and procedure to protect whistleblowers
Omnia Travel has decided to update its internal whistleblower policy and related procedures and bring them in line with the latest European legislation (=European Directive 2019/1937 “on the protection of persons reporting breaches of Union law”) and with its transposition into Belgian law.
This legislation has a dual purpose:
When processing these reports, Omnia Travel naturally takes into account rights of all data subjects, so that our procedures are in line with existing regulations (such as The Protection of Privacy, among others).
We expect that this revised whistleblower policy, along with the approachability and user-friendliness of a new tool, will further support the Omnia Travel speak-up culture and make it more efficient.
This Whistleblower Policy is effective immediately and supersedes all previous versions of this policy and associated procedures.
The new regulations distinguish between the personal scope (=who can report?) and the material scope (=what can you report).
Work-related context as a prerequisite
You can only be legally recognized as a whistleblower if the report is made on the basis of information obtained in a “work-related context. And this term is interpreted very broadly.
Therefore, this more detailed(but not exhaustive) overview:
The European directive limits the legal recognition of reports to violations against the 10 areas of Union law:
Belgian legislation has added 2 more domains to these domains recognized by Europe:
Certain internal reports to which the whistleblower regulations (and the resulting protection mechanisms) do not apply, Omnia Travel will nevertheless treat them as strictly confidential, without the reporter – as a result of this report – having to fear any harm from Omnia Travel.
This obviously applies only insofar as the report is made in good faith.
In particular, it concerns reports about:
It is not only about the violations/infringements in the classical sense, but also about:
In addition, at the time of reporting, a reporter must have reasonable grounds to believe that the information on which he relies is correct.
Whistleblower regulations distinguish between 3 types of reporting channels:
The reporter freely chooses which reporting channel he or she deems most appropriate.
This is put forward not only within Omnia Travel, but also by the laws and regulations as the most appropriate reporting channel.
As a whistleblower, you can report internally through all possible communication channels (= by letter,e-mail,telephone, personal conversation,…)
We list the 4 most important ones below:
Reporting through the Omnia Travel website (=preferred channel)
Through our external website, you will be directed to a protected page, where you can quickly and easily register reporting (=Record system for unethical acts’).
Reporting via the group mailbox ‘Klokkenluiders@omniatravel.be’
The reports received in this mailbox will be registered by the HR officer.
Compliance as central point of contact
Given its legally protected independence, the Compliance department acts as the reporting manager (=point of contact), where all whistleblower reports and notifications are received, monitored and stored. Other entities/persons are required to immediately forward all incoming reports of violations received by themselves to the Compliance Department.
Compliance ensures that any investigation of a report is always conducted in complete independence and that this investigation is always conducted both “à charge” and à decharge, with the confidentiality of the reporter’s identity strictly guaranteed (see below).
Notification of receipt to the reporter
Within 7 calendar days, if the reporter provides his/her details, he/she will receive confirmation of the report, with a brief explanation of what the next steps are and whether or not the report is ‘worthy of protection’ according to the scope of the law.
Within 3 months at the latest, the reporter will also receive feedback on the results of the investigation carried out as a result of his/her report, provided that this report falls within the legal scope of a whistleblower regulation.
A whistleblower may also decide to report directly to an external channel (such as the NBB,the FSMA, or the new Belgian whistleblower authority, yet to be established), in particular when:
This is allowed only if:
It goes without saying that any directive or conduct is totally impermissible if it impedes, prevents or prohibits persons from making a report (or disclosure) in accordance with these principles. Moreover, this may give rise to criminal sanctions.
The identity of the reporter who makes a report in good faith remains strictly confidential. His or her identity, as well as the information from which the identity can be inferred, can be disclosed only in a very limited number of legal cases to persons other than those authorized to receive, investigate and follow up on the report:
Omnia Travel guarantees that it will not treat whistleblowers adversely or take any adverse action as a result of reports made in good faith.
A person who makes a report in good faith cannot be prosecuted under either civil, criminal or disciplinary law because of the report ( or disclosure) about (possible) violations. Nor can any professional sanction pronounced in this situation as a result of such a report. Whistleblowers also cannot be held liable for acquiring or accessing the information reported (or disclosed) unless such acquisition or access constituted a criminal offense in and of itself.
Retaliation, suspension, dismissal, demotion ( or withholding of promotion), non-renewal of contracts, withholding of training, actual retaliation, threats, discrimination and/or other forms of unfair treatment toward the whistleblower as a result of this type of reporting (or disclosure), will always be considered a serious violation of these principles.
In the event of breaches of whistleblower protection, appropriate actions will be taken to safeguard the whistleblower’s position, while the legally defined protections afforded to the whistleblower remain unaffected.
The whistleblower must not abuse the reporting procedure by making malicious, frivolous or dishonest reports (= e.g., by intentionally and knowingly providing false or misleading information).
If the investigation conducted reveals that intentionally and knowingly false or misleading information is reported, the reporter is not entitled to the protection and appropriate sanctions may be imposed (=including those provided for in the Labor Code or in other applicable laws). Moreover, any person harmed by such reports (or disclosures) has the right to seek damages.
Omnia Travel also guarantees protection of the person to whom the report relates. The reporting manager within Compliance will balance the interests and rights of all parties involved. The internal investigation related to the report will be conducted in an independent and impartial manner, taking into account both incriminating and exculpating elements.
In addition to the legal obligation related to confidentiality, the person concerned has the right to information about the violations attributed to him/her. He/she also has the right to information in order to share his/her own point of view and exercise his/her right of defense. If necessary, the person may also have the necessary corrections made if certain information in the file is incomplete or incorrect. However, the person concerned may not make copies of data from the report, nor of investigation-related material, findings and/or measures taken; and this regardless of the format or medium in which this information is stored.
In order not to impede the investigation, the right to information may be temporarily suspended or even limited. We do emphasize, however, that also in this context, the identity of the whistleblower can never be disclosed to the person concerned, nor any information from which his/her identity can be directly or indirectly deduced. Deviations from this gestation can only be made under strict legal conditions (see above).
Reports are investigated by an independent investigation cell. This cell
All researchers in the independent research cell are subject to strict ethical rules related to ensuring appropriate discretion and restraint.
Therefore, Omnia Travel expects every employee to cooperate in good faith with any investigation.
In the event of a conflict of interest or if the independence of an internal or local investigator is compromised, an outside party may be called upon to conduct the investigation.
The Compliance function will report the results of the investigations of the reports, in accordance with the usual reporting lines, to the Executive Committee, without revealing the identity of the whistleblower. It shall ensure that the information, brought from the whistleblowers, is also effectively investigated and that, if relevant, the necessary measures are taken to end the wrongdoing.
The compliance function is also responsible for documenting reporting and ensuring that principles stated in this policy are followed. The Compliance Officers of the relevant entities make an annual report to the management committee.
In order to prove the effectiveness of the whistleblower policy, the Compliance function of the entity concerned keeps a register in which reports of violations are kept. This register does not record the identity data of those involved, but rather what action was taken on the report and why.
1. Introduction
All KBC Group entities are committed to protecting the privacy and personal data of individuals who raise concerns through our whistleblower channels. This Privacy Policy describes how we collect, use and protect personal data in accordance with the General Data Protection Regulation (GDPR) and the European Whistleblower Protection Directive.
2. Scope of privacy statement
This privacy statement is intended to provide a group-wide overview of the main privacy-related principles that apply when KBC Group entities handle whistleblower cases. These general principles may be refined in a local privacy statement. In the event of conflicting clauses between the local privacy statement and this general privacy statement, the local statement will take precedence over this general statement.
3. Data Controller
Since this policy is used group-wide, the position of data controller in connection with the whistleblower policy is placed at the local entity level, which is responsible for the local whistleblower policy. Please refer to the local privacy statements for further details.
4. Types of personal data collected
“We may collect the following types of personal data:
1. Identification data (e.g., name, contact information)
2. Employment information (e.g., job title, department)
3. Details of the reported issue (e.g., description of the incident, parties involved)
4. Any other information provided by the whistleblower “
5. Purpose of data processing
“Personal data collected will be used for the following purposes:
1. To investigate and address reported issues
2. To comply with legal obligations
3. To protect the rights and security of individuals and the organization.”
6. Legal basis for processing
“The legal basis for processing personal data includes:
1. Compliance with legal obligations (Article 6(1)© GDPR)
2. Legitimate interests pursued by the organization (Article 6(1)(f) GDPR) “
7. Retention of data
“Personal data will not be kept for longer than necessary to fulfill the purposes for which they were collected and to comply with legal obligations.
For cases with legal obligations (under legislation), data will be kept for 10 years. In all other cases, data are kept for the remaining months of the year + 1 year.”
8. Data Security and Data Subject Rights
“We implement appropriate technical and organizational measures to protect personal data from unauthorized access, disclosure, alteration or destruction. These measures include: access controls, encryption and regular security reviews. As a data subject, you have several rights regarding your personal data, including:
1. The right to access your personal information;
2. The right to correct or delete your personal data;
3. The right to restrict the processing of your personal data;
4. The right to object to the processing of your personal data;
5. The right not to be subject to automated decision-making.
Keep in mind that the right to access and the right to delete data may be limited if fulfilling these rights would adversely affect the rights and freedoms of others, including the whistleblower.
Finally, you have the right to lodge a complaint about the processing with the competent supervisory authority:
9. Confidentiality and anonymity
We make every effort to maintain the confidentiality of whistleblowers. Reports can be made anonymously and we take all reasonable steps to protect the identity of whistleblowers unless disclosure is required by law.
10. Updates to this Privacy Statement
We may update this Privacy Statement from time to time. Any changes will be communicated through appropriate channels, such as Company websites
11. Contact Details
For questions or comments about this Privacy Statement, please contact dpo@omniatravel.be
If you have specific questions about your own whistleblower report, please contact the Data Protection Officer (DPO)
For Omnia Travel dpo@omniatravel.be
Omnia Travel nv, Mgr. Ladeuzeplein 15, 3000 Leuven, BE 0413646305
