Whistleblower policy

Purpose, Scope and Users

Upinion is committed to maintaining the highest standards of ethics and integrity in all aspects of its operations.

The purpose of this whistleblower policy is to foster a culture of integrity, transparency, and accountability within Upinion, to the benefit of all those involved with the social enterprise. 

This document can be found online on: https://upinion.com/resources/policies/whistleblower-policy/.

This whistleblower policy is designed to encourage and enable employees, volunteers, stakeholders, and other individuals associated with Upinion to report any concerns about potential wrongdoing or unethical behaviour without fear of retaliation.

Reporting Mechanism

Any individual who believes they have knowledge of or have witnessed wrongdoing or unethical behaviour within Upinion is encouraged to report their concerns. 

Reports can be made through the following channels:

• Internal channels:
  • Direct supervisor or manager
  • Executive Board
  • Supervisory Board
  • Incident Report Form
    • ​​Can be done anonymously
  • Dedicated whistleblowing email address
    • [email protected] which is read by Mo Ouass, co-founder of Upinion.
• External channels:
  • Whistleblower Service
    • You can contact the external Whistleblower Service via +31 (0)88 1331 030, [email protected], or directly online (Dutch) if you have reasonable suspicions of a societal misconduct that is not being properly addressed or handled internally at the House for Whistleblowers.
  • External Confidential Counsellor
    • If you require assistance or have doubts about filing a report, Upinion has arranged support and advice through Assist Verzuim. You can contact Jill van der Vegt at 0546-347 721 or [email protected], who is the designated contact for Upinion and can coordinate with an independent confidential counsellor that best fits.

Incident Handling Procedures

• In case of a reported incident, the organization follows the Quality Incidents & Complaints Management Procedure:
  • Incident reports are received, recorded, and reviewed by the executive board, which assesses their seriousness and urgency.
  • The alleged whistleblower is contacted promptly to acknowledge receipt of the report and to gather any additional information if needed. If a report is submitted anonymously through the anonymous options or the Upinion platform, necessary information (like the submitted date) can be obtained in an anonymous way as well. 
  • A thorough and impartial investigation is conducted, involving appropriate personnel and, if necessary, external experts.
  • Based on the findings of the investigation, a decision is made regarding the validity of the report and any necessary measures or sanctions.
  • Closure, Including measures and sanctions: the whistleblower is informed of the outcome, and appropriate measures or sanctions are implemented, which may include disciplinary actions, mandatory training, or other interventions.
  • The Executive Board documents all reported incidents and complaints. All reported incidents and complaints are shared with the supervisory board. A summary of these is included in the annual report, and, where relevant, information may also be communicated to clients and donors in accordance with our commitment to transparency and accountability.
  • Both reported incidents and complaints are documented by the Executive Board and shared with the supervisory board, as well as to other stakeholders like clients and donors where appropriate.

Confidentiality

Reports made under this policy will be treated with the utmost confidentiality to the extent allowed by law.

Confidentiality will be maintained, and the identity of the whistleblower will be protected to the extent possible.

Non-Retaliation

Upinion strictly prohibits retaliation against individuals who report concerns in good faith. Anyone who reports concerns will not face any adverse employment or personal consequences as a result of making a report.

Investigation and Resolution

Reports made under this policy will be promptly and thoroughly investigated. Upinion will take appropriate action based on the results of the investigation, which may include corrective measures, disciplinary action, or referral to legal authorities, as necessary.

Reporting False Claims

Individuals who make reports under this policy that are found to be knowingly false or maliciously intended may be subject to disciplinary action.

Review and Revision

This whistleblower policy will be reviewed periodically and updated as needed to ensure its effectiveness and alignment with best practices.

Adoption

This Whistleblower Policy is effective as of 27 September 2023 and has been adopted by Upinion’s Executive Board.