Companies must determine the “most suitable” person to receive and follow up on reports internally. This could be a: - Compliance officer; - Head of HR; - Legal counsel; - Chief Financial Officer (CFO); - Executive board member or management; - Companies can also outsource the processing of reports.
Whistleblowers should have the ability to check the status of their reports. The reporting person needs to be informed of the receipt of the report within 7 days and provided feedback no later than in 3 months. There is no defined time limit within which the follow-up actions need to be completed.
A reporter should be able to submit reports: - In writing via an online system; - A mailbox or by post; - Orally via a telephone hotline or answering machine system. Companies are also obliged to offer a personal meeting should the whistleblower request it.
Confidentiality and data safety
Companies must ensure that the identity of the whistleblower is kept confidential regardless of which reporting channel is used. The hotline should follow the principles of General Data Protection Regulation (or GDPR). All the involved should be guaranteed protection from data leak: reporting person, concerned person and third people mentioned in the report. Only authorized persons can have access to gathered information.
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