Undesirable behaviour

EUR Holding BV and its subsidiaries believe in the fundamental principle that all persons involved with EUR Holding BV and/or one of its subsidiaries (i.e., employees, members of a supervisory board, students, and clients) should behave respectfully and ethically towards each other as they all have the right to a safe and harmonious workplace and study environment. Nonetheless, incidents may occur and it is crucially important to have a clear procedure for reports and complaints of undesirable behaviour and (suspected) cases of misconduct within the organisation.

Prevention and deterrence against undesirable behaviour

EUR Holding BV and its subsidiaries conduct a policy aimed at preventing and deterring undesirable behaviour, in particular sexual harassment, bullying, discrimination, aggression (including intimidating behaviour), and violence in the workplace and the study environment. Undesirable behaviour is behaviour which:

  • creates an unpleasant, hostile, or even threatening workplace or study environment; and/or
  • has a detrimental effect (physically or mentally) on the person subjected to the undesirable behaviour; and/or
  • obstructs or disadvantages the person who is subjected to the undesirable behaviour, either wholly or partially, in relation to access to facilities, benefits, and opportunities associated with the person’s work or study.

Undesirable behaviour within EUR Holding BV and its subsidiary companies might not only occur between employees, but also between employees and students, between students, between employees and persons working for a client of EUR Holding BV (and/or subsidiaries), and between visitors and employees or students of the EUR Holding BV or subsidiary companies.

EUR Holding BV and all its subsidiaries aim to instil a culture of respect into its organisation. Prevention and deterrence against undesirable behaviour are therefore paramount. Prevention requires that undesirable behaviour be identified, addressed, and where necessary disclosed publicly. EUR Holding BV expects every person who perceives undesirable behaviour to make an active and responsible contribution, not only in relation to their own behaviour, but also by taking a vigilant approach towards undesirable behaviour committed against others.

Based on the fundamental principles of respect, integrity, and safety applicable within their organisation, EUR Holding BV and its subsidiaries seek to prevent undesirable behaviour and to handle reports and complaints about such behaviour in an appropriate manner. In this context, a Confidential Counsellor has been appointed, who will give advice and counselling to people who have been confronted by undesirable behaviour. Furthermore, the CEO of EUR Holding BV has introduced the Regulations for Reports and Complaints about Undesirable Behaviour of EUR Holding BV.

Confidential Counsellor

EUR Holding BV has a Confidential Counsellor in the person of Miriam Heemskerk MSc. She can be contacted via the email address confidential-counsellor@holding.eur.nl.

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. 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