Whistleblowing

WHISTLEBLOWING PROCEDURE

 

 

1. Introduction

1. General Introduction

This whistleblowing procedure outlines the process by which individuals can report concerns or observations related to unethical behavior, violations of company policies, or any activity that contradicts our principles. Le Nouveau Chef is committed to maintaining the highest standards of transparency, accountability, and social responsibility. This procedure is designed to provide a secure and confidential channel for employees and other internal and external stakeholders to voice their concerns without fear of reprisal. It also sets out the role and responsibilities of Le Nouveau Chef’s confidential advisor.

2.  Purpose and Aim

The purpose of this whistleblowing procedure is to ensure that any unethical practices, breaches of company policies, or actions that undermine our principles are identified, investigated, and addressed promptly. The aim is to foster an environment of trust, integrity, and accountability, aligning with B Corp principles and our commitment to sustainable business practices.

3. Responsible Person(s)

The confidential advisor, appointed by the board of directors, is responsible for overseeing and managing the whistleblowing process. The confidential advisor has taken an oath to keep sensitive information strictly confidential and ensure that all reports are handled impartially, confidentially, and with the utmost discretion. Information will only be shared if it is deemed necessary for the investigation or with the consent of relevant stakeholders.

 

2. Scope 

What can be reported

This procedure applies to reports concerning:

• Fraud, corruption, or financial misconduct
• Violations of applicable laws or regulations
• Serious breaches of Le Nouveau Chef's Code of Ethics
• Health, safety, or environmental risks
• Human rights violations or labor abuses in operations or supply chain
• Misuse of company assets or confidential information
• Any other serious misconduct that affects the public interest or the integrity of Le Nouveau Chef
  

This procedure is intended for reports of serious misconduct or wrongdoing that affect the wider public interest. Personal employment complaints (such as conflicts with colleagues, dissatisfaction with working conditions, or individual HR matters) should be directed to the Internal Grievance Procedure. If you are unsure which procedure applies, contact the confidential advisor.

3. Process

3.1 Process structure

The whistleblowing process comprises five key steps:

1. Reporting: submission of a concern through designated channels
2. Initial Review: assessment of credibility and relevance by the confidential advisor
3. Investigation: thorough investigation if warranted
4. Resolution: appropriate actions based on findings
5. Communication: findings and outcomes communicated to relevant stakeholders

3.2 Process Steps

Step 1: Reporting (Anytime) 

• Reports can be submitted via the designated reporting link or by email to the confidential advisor (see section 1.3).
• Internal reporters may submit anonymously; external reporters may also submit anonymously. A fully anonymous external channel will be introduced in future. 
• Reports should include individuals involved, dates, locations, and any supporting evidence.
• If contact details are provided, the confidential advisor will send an acknowledgement within 3 working days, including the next steps in the process. 

Step 2: Initial Review (Within 5 working days)

• The confidential advisor reviews each report as promptly as possible to assess its credibility and relevance.
• A preliminary determination is made on whether the report falls within the scope of this procedure.
• If the report falls outside scope (e.g. a personal employment complaint), the reporter is informed and referred to the appropriate procedure.
  

Step 3: Investigation (Within 40 working days of step 2)

• If the report warrants further investigation, the confidential advisor initiates a comprehensive and impartial investigation.
• Relevant parties are interviewed, and evidence is collected to establish the facts.
• The reporter is kept informed of progress. If the investigation cannot be concluded within 40 working days, the reporter is notified with an updated timeline.
• Maximum total investigation period: 3 months (in accordance with the Wet bescherming klokkenluiders).

Step 4: Resolution (Within 5 working days of step 3) 

• The confidential advisor determines the appropriate actions based on the investigation findings.
• Actions may include corrective measures, policy adjustments, employee training, or other necessary interventions.
• Where applicable, findings are escalated to the Board of Directors.

Step 5: Communication (Within 5 working days of conclusion)

• The confidential advisor communicates the findings and outcome to the relevant stakeholders, ensuring confidentiality is maintained.
• The reporter is informed of the outcome and notified when the matter has been resolved.
• If necessary, steps are taken to address any potential retaliation against the reporter.

4. Protection of the Reporter

• Le Nouveau Chef strictly prohibits any form of retaliation against individuals who report concerns in good faith. Raising a concern in good faith means providing honest and accurate information, even if it later turns out to be incorrect. Reports made in good faith cannot be used as the basis for disciplinary action or discrimination.
• Employees who believe they have experienced retaliation should report this immediately to their supervisor or the confidential advisor. Le Nouveau Chef will investigate all retaliation complaints thoroughly.
• The identity of the reporter will be kept strictly confidential and will not be disclosed without the reporter's consent, unless legally required.
  

5. External Reporting Channel

• In addition to the internal reporting channel described in this procedure, reporters may also contact external bodies:
• Huis voor Klokkenluiders (House of Whistleblowers)- the independent Dutch authority for whistleblower reports: www.huisvoorklokkenluiders.nl
• Relevant regulatory authorities, depending on the nature of the concern (e.g. Dutch Authority for the Financial Markets, Dutch Labour Authority)
• The external channel is available if the internal procedure cannot be used safely, has not led to an adequate response, or if there are grounds to believe the misconduct poses an immediate or serious risk.
  
• This Whistleblowing Procedure aligns with the Wet bescherming klokkenluiders (Dutch Whistleblower Protection Act) and Le Nouveau Chef's B Corp commitments, promoting transparency, accountability, and ethical conduct throughout our organization.
• Online:
  At Le Nouveau Chef, we commit to an environment of trust, integrity, and accountability. Our whistleblowing procedure outlines the possibilities to report concerns related to unethical behaviour, policy violations, or actions conflicting with our principles. Transparency and social responsibility are important values to us. The procedure provides a secure and confidential channel for employees and other stakeholders, within and outside our organization, to voice concerns without fear of reprisal. 

• Confidentiality
  We take confidentiality seriously. Your identity and the details of your report will be handled with the utmost care, ensuring your privacy is protected throughout the process. We encourage open communication and value your commitment to ethical conduct. 
• Purpose and aim
  The purpose of this whistleblowing procedure is to identify, investigate, and address unethical practices promptly. Our aim is to uphold the highest standards of integrity and contribute to a just and sustainable business environment. Aligned with social and environmental principles, we are dedicated to maintaining transparency, accountability, and ethical conduct throughout our organization.
• Responsible person(s)
  A confidential advisor, appointed by the board, oversees the whistleblowing process. This individual ensures impartial, confidential, and discreet handling of reports. Information is shared only when necessary for investigation or with the consent of relevant stakeholders. For employees and other internal stakeholders reporting is possible through the feedback box in the HR section of Le Nouveau Chef’s intranet. External stakeholders can share any feedback through Fleur@lenouveauchef.com

Scope

What can be reported
The whistleblowing procedure applies to reports concerning:

1. Fraud, corruption, or financial misconduct
2. Violations of applicable laws or regulations
3. Serious breaches of Le Nouveau Chef's Code of Ethics
4. Health, safety, or environmental risks
5. Human rights violations or labor abuses in operations or supply chain
6. Misuse of company assets or confidential information
7. Any other serious misconduct that affects the public interest or the integrity of Le Nouveau Chef

This procedure is intended for reports of serious misconduct or wrongdoing that affect the wider public interest

Process
Whistleblower Process Structure: The whistleblowing process at Le Nouveau Chef includes reporting, initial review, investigation, resolution, and communication.

How a report is handled:

Step 1: Reporting (anytime)

1. Submit via an email to the confidential advisor: Fleur@lenouveauchef.com
2. Reports may be submitted anonymously
3. Include who was involved, dates, locations, and any evidence
4. If you leave contact details, you'll get an acknowledgement within 3 working days

Step 2: Initial review (within 5 working days)

1. The confidential advisor checks the report's credibility and scope
2. If it falls outside scope, you'll be informed and referred to the right procedure
   

Step 3: Investigation (within 40 working days)

1. An impartial investigation: interviews, evidence, establishing the facts
2. You're kept informed; if it takes longer, you'll get an updated timeline
3. Maximum total period: 3 months (Wet bescherming klokkenluiders)

Step 4: Resolution (within 5 working days)

1. Appropriate actions are decided: corrective measures, policy changes, training, or other steps
2. Where relevant, findings are escalated to the Board of Directors

Step 5: Outcome (within 5 working days)

1. You're informed of the outcome and when the matter is resolved
2. Steps are taken to prevent any retaliation against you

The Whistleblowing procedure is part of our ongoing commitment to social and environmental responsibility, emphasizing transparency, accountability, and ethical conduct in our organization. Upholding high standards of integrity, we believe in an open channel to report concerns to contribute to a just and sustainable business environment.

Protection

1. Anyone who reports a concern in good faith is protected against retaliation. Reporting in good faith means sharing honest information, even if it later proves incorrect.
2. For suppliers and their workers, this means a report will never lead to reduced or cancelled orders, ending the relationship, or any other adverse action.
3. Your identity is kept strictly confidential and will not be shared without your consent, unless legally required. You may also report anonymously.
   

External Bodies: If our process cannot be used safely or has not led to an adequate response, you may also contact an independent body:

1. House of Whistleblowers,  the independent Dutch authority for whistleblower reports: www.huisvoorklokkenluiders.nl
2. Relevant regulatory authorities, depending on the nature of the concern (e.g. Dutch Authority for the Financial Markets, Dutch Labour Authority, relevant labour or regulatory authority in your own country)