Whistleblower Policy
Updated: 1st January 2025
- Purpose
This Whistleblower Policy establishes a framework to encourage and enable employees, contractors, and other stakeholders to report any concerns or suspicions of unethical, illegal, or improper conduct within the organization. It aims to ensure compliance with Austrian laws, including the Whistleblower Protection Directive (EU Directive 2019/1937), and promote transparency and accountability within the company. - Scope
This policy applies to all employees, independent contractors, suppliers, and business partners associated with the insurance brokerage. - Definitions
- Whistleblower: Any person who reports misconduct, violations of laws, or unethical behavior in good faith.
- Misconduct: Includes but is not limited to fraud, corruption, bribery, conflicts of interest, breaches of data protection laws, and violations of insurance regulations.
- Good Faith: The sincere belief that the information provided is true and pertains to misconduct.
- Whistleblower: Any person who reports misconduct, violations of laws, or unethical behavior in good faith.
- Reporting ChannelsWhistleblowers may report concerns through the following channels:
- Dedicated Email: hermann@fried.solutions
- Written Reports: Unisure Solutions, 1150 Wien, Eduard Suess Gasse 10
Reports may be submitted anonymously if preferred.
- Protection Against Retaliation
The company strictly prohibits retaliation against whistleblowers. Retaliatory acts, such as dismissal, demotion, harassment, or discrimination, are subject to disciplinary action, up to and including termination. The company complies with Austrian laws protecting whistleblowers from adverse consequences. - Investigation Process
- 1.Acknowledgment: Upon receiving a report, the company will acknowledge its receipt within three business days.
- 2.Preliminary Review: The Compliance OXicer will conduct a preliminary review to determine the validity and scope of the report.
- 3.Full Investigation: If warranted, a thorough investigation will be carried out, ensuring confidentiality and impartiality.
- 4.Resolution: Appropriate actions will be taken based on the investigation findings. The whistleblower will be informed of the outcome, subject to legal and confidentiality constraints.
- 1.Acknowledgment: Upon receiving a report, the company will acknowledge its receipt within three business days.
- Confidentiality
The identity of the whistleblower and the details of the report will be kept confidential to the fullest extent possible, consistent with the need to conduct a thorough investigation and comply with legal obligations. - False Reporting
Reports made in bad faith or with malicious intent are prohibited and may result in disciplinary action, including termination of employment or contractual agreements. - Training and Awareness
The company will provide regular training to employees on whistleblowing rights, protections, and procedures to ensure awareness and foster a culture of integrity. - Policy Review
This policy will be reviewed annually and updated as necessary to remain compliant with Austrian and EU laws and to address emerging risks. The review will be documented.