Integrity policy

0. Informal reporting

You can discuss your suspicion of an integrity violation confidentially with a staff member, the integrity complaints manager, the integrity officer, the integrity advisor or a board member at any time. They can inform and guide you trough the formal reporting procedure if you wish.

The comprehensive complaints handling procedure can be found here.

1.      Confidential hotline

Before a formal report or complaint is submitted, an informal report is possible. A reporter can at any time confidentially discuss his/her suspicion of a violation with a staff member, manager, director, complaints manager, the integrity adviser or board member. They can inform and guide the reporter through the formal reporting procedure if desired.

Through our first-line hotline, you can formally file an integrity complaint. This complaint concerns something you have experienced yourself or something you have seen that violates our code of conduct.

Through this procedure, a complaint or notification is admissible if:

• it relates to breaches of integrity committed by Solidagro, including its directors, employees and volunteers in the performance of their duties.
• the complaint or notification was made by an interested party, such as every employee, director, partner and beneficiary of Solidagro.
• the facts of the complaint took place no more than 10 years ago.
• the complaint or notification was made via Solidagro's first-line hotline.
• the complaint was not filed anonymously.
• it does not concern a complaint or report that was previously made and to which adequate action was taken.

The hotline is back here. The report will then reach our complaints manager (Paul Verbeke) and our external consultant (Birgit De Clerck).

2.      Receipt confirmation

After receiving the complaint or notification, the complaints manager sends an acknowledgement of receipt to the reporter within 5 working days.

3.      The preliminary investigation

The preliminary investigation is conducted by Paul Verbeke, the complaints manager and president of Solidagro. Through the preliminary investigation, the complaints manager determines whether an investigation should be conducted following a report and assesses the admissibility of the complaint or report.

The complaints manager prepares a report of the preliminary investigation. Based on his findings, in connection with the admissibility assessment, the genuineness and provability of the alleged facts, the complaints manager makes a proposal of an investigation or not.

The complaints manager always carries out an independent analysis and provides timely feedback to the reporter. If necessary, he will check with the integrity officer (Tim De Roeck) or members of the board, but only after agreement with the reporter. The integrity counsellor (Elisa Tondeleir) is not informed about the preliminary investigation or the investigation of the complaint or report.

If the preliminary investigation shows that there are no grounds for an investigation, the complaints manager informs the complainant with a brief justification.

4.      The study

Based on the facts and data of the investigation, it is decided which persons will be involved and whether the investigation will be conducted internally or externally. Discretion and confidentiality are guaranteed to the maximum.

The complaints manager always applies the following principles:

• confidentiality of information;
• proportionality;
• treatment within a reasonable time;
• absence of bias;
• protection of the parties involved.

The facts, sensitivity, risk and complexity of the complaint or report are always assessed against these principles. The complaints manager always takes an independent, confidential and respectful position towards all parties involved.

Deviations from keeping the reporter's identity confidential can only be made with the express consent of the parties involved or when required by law. 

5.      Handling and follow-up of the investigation

If the investigation shows that possible criminal offences were committed, advice may be sought from an internal or external expert, after which judicial authorities will possibly be seized. If the investigation shows no integrity violation was committed, no measure will be imposed.

Appropriate measures are taken towards the offender. These obviously depend on the investigation and can vary widely. Appropriate measures include a reprimand or warning, immediate dismissal, mediation or amicable settlement.

Determining the sanction is done by the complaints manager, possibly after internal or external advice.

The outcome of the complaint investigation shall be communicated to the reporter and, if applicable, the victim of the violation. Reasonable time must be respected for this purpose. The exact form of follow-up towards the victim depends on the facts, circumstances and the outcome of the investigation. In any case, the complaints manager keeps a finger on the pulse after the complaint procedure has been completed.

6. Other reporting channels

A reporter can also contact the central point of contact when:

• A thorough and correct investigation is unlikely
• There was no follow-up to a report to the first-line reporting point
• The investigation after reporting was not thorough or correct
• The necessary measures were not taken

This is only possible for reports of abuse, which are defined as sexual exploitation, sexual abuse or sexual harassment, and not for financial or integrity violations. The admissibility of the report is assessed by the central point of contact. When assessing the report, the central point of contact will contact the organization involved to verify:

• The follow-up to the report
• The measures that were taken
• And if necessary, the integrity procedures

The organization involved has a duty to cooperate in this. If the organization involved does not meet the requirements, the central reporting point will forward a report with recommendations.