This VAB group ethical and fraud policy forms a part of general risk management, with the intention of ensuring that VAB takes all the necessary steps to protect the good name and reputation of the VAB group entities and of its employees, customers, suppliers and other stakeholders.

VAB group therefore wishes to create, promote a corporate culture characterised by honesty and openness, whereby all employees (the “whistleblowers") are able to report potential fraud or other serious malpractices at the earliest possible stage without fear of reprisal, and whereby whistleblowers are guaranteed fair treatment and their suspicions will be properly investigated.

VAB guarantees the protection of the identity of whistleblowers and will protect them against all possible negative consequences of reporting a suspicion in good faith in the manner as set out in the internal regulations. In accordance with these principles, VAB also protects and respects the rights of the person to whom the notification relates.

To make sure that a thorough investigation can take place, whistleblowers must to the extent possible mention the following information in their reporting:

• the name of the entity where the matter has occurred.
• the identity and contact details of the whistleblower;
• a description of the case with all known relevant facts (what has happened, where, what specific behaviour gave rise to the reported suspicion, who is involved, etc.);
• an indication of why the matter is reported;
• an indication as to whether the matter has already taken place or could take place in the future;
• an indication of how the whistleblower gained knowledge of the incident or the situation;
• whether there are other persons involved or witnesses;
• if the whistleblower has any substantiating information;
• if the whistleblower has discussed the matter with someone else, and if so, with whom;
• an estimate of the amounts involved;

A local independent investigation unit has been set up and authorised at VAB to investigate malpractices and fraud, and to ensure that the investigations are carried out in good time, effectively, confidentially, professionally and objectively. If the ethical and fraud policy of the VAB group is not complied with, disciplinary action can be imposed as provided for in the applicable regulations on the basis of which the local working relationship is controlled, and that is applied after an impartial, confidential and fair investigation.

The investigators are subject to strict ethical rules, in particular with regard to respecting the necessary discretion and restraint. Every employee must cooperate on these investigations in good faith. If appropriate (for example if there is a possible conflict of interest, or if the independence of an internal or local investigator can be endangered), an external party can be used to carry out the investigation as mentioned above.

By e-mail to Risicobeheer@vab.be.