Misconduct involves (suspected cases of) illegal or immoral practices within EUR Holding BV and its subsidiaries, which constitute a violation of significant social interests. Misconduct can include amongst other things:
- (an imminent) a criminal offence, such as theft, corruption and forgery;
- (an imminent) a breach of legislation and regulations or policy rules of EUR Holding BV and its subsidiaries;
- (an imminent) a danger to public health, safety, or the environment;
- (an imminent) deliberate misleading of public bodies; or
- (an imminent) deliberate concealment, destruction, or manipulation of information about such circumstances or offences.
EUR Holding BV (including its subsidiary companies) 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 organization within each subsidiary company and EUR Holding BV as a whole, 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 or one of its subsidiary companies (LLCs).
EUR Holding BV has an independent Confidential Counsellor in the person of Miriam Heemskerk MSc. She can be contacted via the email address firstname.lastname@example.org.
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 (alleged) cases of misconduct within EUR Holding BV and its subsidiary companies (LLCs). Based on its findings, the COOM provides the CEO of EUR Holding BV or of the subsidiary company involved in the case advice and recommendations on what measures to take in order to resolve complaints and reports. If the CEO is himself involved in the complaint (as complainant or subject of the complaint), then Supervisory Board Chair will assume the duties of the CEO during the complaint procedure.