Whistleblower’s reporting procedure

Integrity and compliance with internal and external rules is of the highest priority for BAS. Our aim is to prevent any violations of these values and rules, however, for the violations that do occur, it is essential that these are identified, clarified, and eliminated.
Any (suspected dangers of) violations within BAS with major or social consequences can be reported via our whistleblower form. In principle, this concerns dangerous, immoral or illegal practices that transcend the level of a single case or a few personal cases, for instance because of the seriousness of the situation, its scope or its structural character.
Reports can be made by persons in a work-related context with BAS at any time. Information received through this channel is thoroughly investigated and resolved depending on the type of violation.
The whistleblower system ensures that both the whistleblowers as well as the persons implicated are protected. An investigation only is started after a very careful examination of the facts and a reasonable suspicion of a regulatory violation. The entire process is strictly confidential, secret, fair and conducted sensitively.

Whistleblowing policy

For a summary of the whistleblowing policy, click here
For the full version of the whistleblowing policy, click here

Whom can use it

Reporters may make reports regarding:

Dutch BAS company

German BAS company

• An act or omission in which the public interest is at stake in a breach or risk of breach of a statutory regulation or internal rules involving a concrete obligation and adopted by an employer pursuant to a statutory regulation;
• Danger to public health, the safety of persons, damage to the environment or to the proper functioning of the public service or an enterprise as a result of improper conduct or failure to act;
• A violation or risk of violation of Union law.

• Violations of criminal provisions;
• Violations punishable by a fine (i.e. administrative offences) if the violated standard serves to protect life, limb or health or to protect the rights of employees or their representative bodies;
• An act or omission where the social interest is at stake in a violation or risk of a violation of a legal regulation or internal rules involving a concrete obligation and established by an employer pursuant to a legal regulation;
• All violations of federal and state legislation taken to implement certain European regulations, as well as violations of directly applicable EU legal acts in various areas;
• Violations falling under § 4d paragraph 1 sentence 1 of the Financial Services Supervision Act, unless something else follows from § 4 paragraph 1 sentence 1;
• Violations of tax legislation.

(Danger of) potential abuses can be reported at any time. The internal reporting procedure is accessible to all natural persons in a work-related context to report abuses they (prefer) not to report to their manager.
The definition of violations of European Union law can be found in annex one of our whistleblowing policy.

What the procedure is not meant for

The whistleblowing policy is only intended for reporting (suspected danger of) abuse, an irregularity or possible infringements of company rules, national law and European Union law. The whistleblower policy is not intended for:

• Complaints relating to BAS about any of its products or services. For these you can use the Complaints Procedure as outlined in the general terms and conditions;
• Abuses or complaints about BAS customers;
• The handling or reporting of personal grievances of employees without danger for the safety and/or health of the concerned employee(s) .

Other reporting channels

You are authorised to make your notification both in writing and verbally and both physically and online. To make a written report on paper, please address your report to:

Please note; state exactly what your report is about, which BAS organisation and/or person involved and in which capacity you are making the report.

If you prefer to make the report in a meeting at the office, please make an appointment.

Before submitting a report

• Providing your email address is helpful, even if you are making an anonymous report. We will use this email address to contact you if we need more information. Your details will be treated with the strictest confidentiality. Please note: it is not compulsory to enter your e-mail address.
• Please be aware that if you do not provide contact details, we will not be able to contact you. As a result, we might be unable to conduct further investigations into your report. If you have provided contact details, we might contact you to obtain further information
• If your report relates to actual or suspected abuses and irregularities that have taken place at a subsidiary of BAS Group, please be sure to state this clearly
• Please provide a comprehensive description of the situation and the people involved. If we receive more context we can investigate the matter better

If you are a Dutch BAS employee (note: this does not apply to every Reporter and nor for Employees working for a German BAS company) and want to discuss your issues with an external confidant you can contact:

Name: Moniek van den Berg
Company name: BakxWagenaar
Email: vertrouwenspersoon@bakxwagenaar.com
Tel: +31 (0)492 218800 / +31 (0)6 38183258

This external confidant will keep your details confidential and will not share any information about your report without your explicit consent.

Reporting the incident

Make a report of a suspected wrongdoing: