Obligation to report
Employees are obliged to report irresponsible, unethical or unsound conduct of other Q-Park employees. In this, a distinction may be made between notification of incidents or of abuses. If unintentional, a breach of the code will be treated as an incident. An employee is expected to report such an incident him/herself.
However, should that not be the case, other employees will be expected to report the incident. Any incitement to breach the code must also be reported. A deliberate breach of the code by one or more persons will be considered as abuse.
Responsibility on behalf of the person reporting
Employees must not be discouraged from reporting an incident or an abuse. The employee must be confident that his/her report will be treated very carefully and confidentially at a sufficiently high level in the organisation and that it will eventually lead to a decision. Nor may a report made in good faith lead to negative consequences for the individual who made that report.
The individual making the report will always be informed of the major conclusions of the final investigation, even if it transpires that the notification was unjustified. If the investigation concludes that the individual making the report acted otherwise than in good faith and deliberately made a false notification, disciplinary measures will be taken.
Who to report to
Incidents and abuses should preferably be reported to the Code Supervisor but an employee may instead report the incident to his/her immediate superior or a manager with a higher position in the organisation. The latter will inform the Code Supervisor in consultation with the individual making the report.
It is not possible to file a report anonymously
Anonymous reports of incidents or abuse are difficult to process because it is not possible to consult with the individual making the report. The identity of the individual making the report must be known to the person receiving the report or to the Code Supervisor because of the risk of false reports.
Employees who have to file a report may call on the whistleblower scheme if they fear for their own position within the organisation. In that case those to whom the report is made must keep the identity of the individual making the report confidential.
The Code Supervisor called in must record the position of the individual making the report in the organisation at that point, including the salary and additional terms and conditions of employment, any commitments already promised and/or where applicable, previously defined career prospects within the organisation.
This will give the individual making the report the assurance (for a report filed in good faith) that his/her future prospects are secure.
Procedures on receipt of a report
As soon as a report of an incident or abuse is made known to the Code Supervisor, he/she will document the report in writing in a confidential incident register internal to the company. In documenting the report, the Code Supervisor will treat the details of the individual making the report with the utmost care.
If the individual making the report wishes to make use of the whistleblower scheme this will be noted in the incident register and the Code Supervisor will guarantee the confidentiality of the individual making the report. The progress of the investigation, including the meeting reports, the names of those involved in the matter, the decisions taken during the investigation and the major and other conclusions will be documented in the register.
The Code Supervisor will report on his/her work to the Executive Board at least once a year.
Internal or external investigation
The Code Supervisor will conduct the investigation into the report him/herself or will draw up an investigation plan, with or without the assistance of a third party. Depending on the gravity of the report and the organisation’s relevant policy, the Code Supervisor will involve external investigating bodies in the investigation.
The Code Supervisor will decide whether to start legal action. This can be civil, criminal, or a combination of both. The Code Supervisor will decide on the relevant sequence.
In the event of a breach of the Code of Ethics by an employee, Q-Park will impose sanctions which may vary from a warning to instant dismissal, depending on the gravity of the matter.
Signed by employee