Whistleblowing Policy

This policy ensures that if you encounter something that doesn't feel right, such as serious wrongdoing that affects our people, business, or the world around us, you can share your concerns safely and confidently.

What is Whistleblowing?

Whistleblowing is the disclosure of information regarding a serious wrongdoing. This is different from a personal grievance:

  • Whistleblowing concerns matters of public interest, such as fraud, corruption, environmental damage, human rights violations in the supply chain or breaches of EU or national law.
  • Grievances are complaints against transgressive behaviour someone might experience personally. We kindly ask you to refer to our Internal Grievance Process for these types of issues.

Who Can Report?

The policy is open to any stakeholder in the MR MARVIS value chain, including:

  • Current and former employees
  • Suppliers, contractors and their employees
  • Any person performing work for or on behalf of MR MARVIS

When to Report?

You should make a report if you have reasonable grounds to suspect that a serious wrongdoing has occurred, is occurring, or is likely to occur within the context of MR MARVIS’s operations. You do not need ‘hard proof’: reports should simply be made in good faith.

Examples of reportable concerns:

  • Fraud, bribery or corruption
  • Violations of health and safety
  • Environmental violations or pollution
  • Human rights violations in the supply chain (including child or forced labour)
  • Breaches of applicable laws
  • Serious threats to public health

How to Make a Report?

We have established a dedicated, independent reporting channel to ensure your report reaches the right people immediately.

Email: You can reach our designated Whistleblowing Office at [email protected].

This inbox is managed by the Whistleblowing Team, which consists of a designated representative from our People Team and a representative from our Legal Team. It is not accessible to general staff.

Specialist Support: If a report relates to environmental matters or human rights violations in the supply chain, the Sustainability Team will be involved to provide subject-matter expertise during the investigation and will be added to the Whistleblowing Team.

Anonymity & Confidentiality

Confidentiality: If you choose to share your name, your identity will be strictly protected. It will only be known to the Whistleblowing Team and will not be disclosed to those in your report, unless we are legally required to do so.

Anonymity: Anonymous reports are accepted and will be handled with the same seriousness as identified reports. If you wish to remain anonymous, we recommend using a non-identifiable email address (e.g. a Gmail or ProtonMail account that does not contain your name) or contacting us via the external reporting authority listed below. [We are evaluating the implementation of a dedicated anonymous reporting platform to further strengthen this protection. Updates will be communicated in due course.]

The Investigation Process

Once a report is received, we follow a structured, impartial process:

  1. Acknowledgement: We will acknowledge receipt of your report within 5 working days.
  2. Assessment: the Whistleblowing Team will determine if the report falls within the scope of this policy. If it relates to a personal grievance, you will be redirected to the appropriate channel.
  3. Investigation: If the report is valid, an independent investigator will be appointed. This person will have no prior involvement in the matter reported. For environmental or human rights matters, our Sustainability Team will lead or support the investigation.
  4. Interview: You may be invited to a meeting to provide further details. You are welcome to bring a confidant or legal advisor for support.

Feedback: We will provide you with an update on the progress or outcome of the investigation within 3 months of the acknowledgment date, in accordance with the Whistleblower Protection Act (Wet bescherming klokkenluiders)

Your Protection: Zero Tolerance for Retaliation

At MR MARVIS, doing the right thing should never come at a cost. Any person who makes a report in good faith is fully protected under our internal policy and under Dutch and EU law. We have a zero-tolerance policy for any form of retaliation, including dismissal, demotion, harassment, discrimination, or any other detrimental action. Anyone found to be retaliating against a whistleblower will face immediate internal disciplinary action (which may include termination of employment).

External Reporting

While we encourage you to use our internal channels first so we can address issues promptly, you have the right to report concerns directly to external authorities at any time. Relevant external authorities include:

  • Huis voor Klokkenluiders (Netherlands Whistleblower Authority) – www.huisvoorklokkenluiders.nl
  • The relevant national competent authority for your country of work
  • The European Anti-Fraud Office (OLAF), where applicable

Legal Framework

This Whistleblowing Policy has been established in compliance with:

  • EU Directive 2019/1937 on the protection of persons who report breaches of Union law
  • Whistleblower Protection Act, Netherlands, 2023) (Wet bescherming klokkenluiders)
  • General Data Protection Regulation (GDPR/AVG)