Misconduct involves (suspected cases of) illegal or immoral practices within EUR Holding BV, which constitute a violation of significant social interests. Misconduct can include amongst other things:
- (a threat of) a criminal offence, such as theft, corruption and forgery;
- (a threat of) a breach of legislation and regulations or policy rules of EUR Holding BV;
- (a threat of) a danger to public health, safety, or the environment;
- (a threat of) deliberate misleading of public bodies; or
- (a threat of) deliberate concealment, destruction, or manipulation of information about such circumstances or offences.
EUR Holding BV believes it is important to deal with any suspected cases of misconduct with the appropriate due care. If a case is not handled properly, it could lead to suffering significant harm or damage by the organisation, the person reporting the incident, and third parties. EUR Holding BV therefore wants to create the necessary preconditions to ensure a proper handling and resolution of any misconduct incident. For this purpose, regulations have been drawn up which:
- are formulated in such a way that the internal reporting of misconduct is seen as a positive contribution towards an improved functioning of the organisation, that reports of incidents are investigated seriously, and that appropriate measures are taken where necessary;
- ensure that employees acting in good faith are given the appropriate legal protection if they file a report or lodge a complaint in accordance with the set procedures. The regulations in this way also protect employees against any negative consequences or retaliation from reporting an incident.
The EUR Holding BV Regulations on Reporting Misconduct describe the available options and the procedure to follow in the event that an employee, student, contract partner or third party wishes to report a (suspected) case of misconduct within EUR Holding BV.
EUR Holding BV Confidential Counsellor
EUR Holding BV has an independent Confidential Counsellor in the person of Miriam Heemskerk MSc. She can be contacted via the email address email@example.com. She will carry out this task in addition to her regular duties as student advisor iBCOM at ESHCC.
The Confidential Counsellor is the first point of contact for confidential counselling and advice on a case of misconduct, or if an employee is involved in a conflict where the standard workplace conflict procedures have not led to a satisfactory resolution, for example.
The Confidential Counsellor is impartial, and acts as a sounding board and intermediary between EUR Holding BV (and its subsidiaries) and employees, students, and contract partners. Confidentiality and anonymity will be maintained at the request of the relevant person insofar as this is permitted under the applicable legislation and regulations.
Complaints Committee: Committee on Undesirable Behaviour and Misconduct (COOM)
EUR Holding BV has a Complaints Committee, namely the Committee on Undesirable Behaviour and Misconduct (COOM). This committee investigates, evaluates, and handles all written complaints of undesirable behaviour and reports of cases of misconduct. Based on its findings, the COOM provides the CEO of EUR Holding BV with advice and recommendations on what measures to take in order to resolve complaints and reports.