Whistleblowing procedure

1. What is an integrity violation?

An integrity violation is an act or omission that constitutes a violation of the regulations, internal rules or procedures applicable to STIB-MIVB and represents a potential threat to, or a violation of the public interest.

This means that the violation you report should not solely relate to your personal situation or interest. For example, a public interest violation involves a threat to life, health, or safety of individuals or to the environment and/or represents a serious breach of professional obligations or proper management within STIB-MIVB.

1.1. What can you report?

You can report a violation that has already occurred, is occurring or is about to occur.

For example, the following could be reported:

• Misappropriation of assets;
• Irregularities in a public procurement procedure;
• Conflict of interest;
• Abuse of authority;
• Unfair competition;
• Violation of privacy.

1.2. What can you not report?

Some areas are already subject to specific regulations and have dedicated reporting procedures. They are therefore outside the scope of this procedure.

These are the following situations:

• Moral harassment, violence at work and sexual harassment at work;
• Discrimination (in a wide sense: based on gender, ethnicity, age, sexual orientation, etc.);
• Interpersonal conflicts.

If, as a STIB-MIVB employee, you encounter one of the situations mentioned above, you must contact the competent authorities. For information, these authorities include your manager, human resources, a prevention advisor (SIPPT),  the psychosocial prevention advisor , the  Well-Being team , a "trusted person".

2. Who can make a report?

Any person who, for justified reasons, intends to report an integrity violation in a professional context may use the whistleblowing procedure.

This includes:

• STIB-MIVB employees, including volunteers and interns, whether paid or not, as well as union representatives;
• External consultants;
• Members of the administrative, management, or supervisory bodies of STIB-MIVB;
• Employees of contractors, subcontractors, and suppliers of STIB-MIVB;
• Workers whose employment relationship has ended, as well as candidates who have applied for a job at STIB-MIVB.

Being a whistleblower requires total objectivity. Reporting an integrity violation should not be done carelessly. Anyone deliberately making a false or inaccurate report is exposed to disciplinary and/or criminal sanctions. Likewise, any person obstructing a whistleblower, or providing false information during an investigation, is also exposed to disciplinary and/or criminal sanctions.

3. How to make a report?

Have you witnessed or do you suspect an integrity violation? You can report it directly via the internal channel set up by STIB-MIVB.

You can report it by sending an email to the dedicated email address managed by the Internal Audit department: integrity@stib-mivb.brussels ; or by phone at 0472/550.880.

The report will be followed by a confirmation email, an internal analysis and feedback, in accordance with legal deadlines. These stages and deadlines are summarised in the diagram below.

Each report will be examined with all due diligence, impartially and with the highest level of confidentiality.

To ensure that we can properly process your report, we encourage you to provide us with your identity and contact details (name, phone number, e-mail address). You may, of course, also choose to make your report anonymously. In this case, your report cannot be made by phone; we invite you to create a dedicated anonymous email address.

If you have legitimate concerns that your report may not be processed properly, you can contact the Brussels Ombudsman.

4. What should the report contain?

To ensure that the report can be properly processed, all relevant information and documents required to understand the report must be provided.

The following information is mandatory:

If some information is missing, Internal Audit may contact you directly or invite you for a confidential interview to complete your report. You can also spontaneously complete your report via the channels mentioned in point 3.

5. What protection do you benefit from?

STIB-MIVB aims to create a safe environment where it is possible to report an integrity violation with trust and without fear of reprisals. To achieve this, the following measures have been implemented in accordance with the legislation.

1.1. Confidentiality

The confidentiality of your identity as the whistleblower, and the identity of the persons concerned by the report, is maintained throughout the entire processing of the report, even if the report is transferred to the Brussels Ombudsman. Only the Internal Audit members, including the Trusted Integrity Person, are informed of your identity and the identity of the persons involved.

Your identity can only be revealed to another person or authority if you consent to it, or if STIB-MIVB is legally required to do so (e.g., in the case of criminal offences, the report is transferred to the Royal Prosecutor).

You may provide confidential information as part of your report. In this case, no professional or criminal sanctions may be taken against you. Please note, however, that the information you provide must have been legally obtained.

1.2. Protection against reprisals

Anyone who makes a report in good faith, as well as people who help a whistleblower or any third party related to it, are protected against reprisals.

Reprisals are negative measures taken in response to a report. For example, the following measures are reprisals:

• Dismissal
• Change of workplace;
• Change of work schedule
• Negative evaluation;
• Disciplinary action;
• Reprimand;
• Harassment.

Please note that this protection only applies if you are acting in good faith. This means that you  reasonably believe that the facts reported are true and that they lie within the scope of the regulation. This protection remains valid even if, after analysing the report, the facts you reported have not been proven.

1.3. Personal data protection

To process your report, we may collect the following personal data:

• Identification data such as your first or last name those of the person concerned by the report;
• Contact details such as your phone number, e-mail address or postal address;
• Data relating to your profession and employment, such as your division and organisational unit.

The personal data you provide us when you make a report is processed in compliance with Whistleblowing legislation but also in compliance with data protection regulations. In particular, Regulation (EU) 2016/679 of the European Parliament and of the European Council of 27 April 2016 on the protection of individuals regarding the processing of personal data and on the free movement of such data (‘GDPR’). In addition, some data may also be collected from other persons. Such data will only be collected if required to process the report.

Once we have processed your report, we will store your data in accordance with the law, i.e. for 10 years from the end of the reporting procedure.

For any questions regarding the processing of your personal data, you can contact dpo@stib.brussels.

6. Need help?

In accordance with the applicable legislation, STIB has named a Trustworthy Integrity Person (TIP). This person is responsible for informing and advising anyone regarding the whistleblowing procedure. Therefore, if you have any doubts about the procedure to follow, if you want to receive advice confidentially, or if you have any other questions, do not hesitate to contact the TIP (Amandine Wouters, amandine.wouters@stib.brussels)

Let's work together for a more ethical and secure work environment!