EDB has the obligation to comply as follows:

1st Provide Easy Access

  • The CEO must ensure publication and easy access on the internet and intranet of the appropriate contact details [i.e. email ID] of the Reporting Officer.

2nd Protect Anonymity

  • All Employees, including members of (senior) management and Reporting Officers, must never attempt to discover the identity of a Whistleblower who has chosen to report a Concern Anonymously.

3rd Prevent Retaliation

The BoD must ensure that a Whistleblower, or any stakeholder, or employee who provides information, who causes information to be provided is protected from Retaliation by:

  • Strictly prohibiting Retaliation. Retaliation is also prohibited if an Investigation shows that the reported Concern, although not grounded, was reported in Good Faith;
  • Educating his/her staff on these specific prohibitions; and
  • Subjecting to disciplinary action, civil action or criminal prosecution any Employee who (attempts to) Retaliate(s) against a Whistleblower or against any Employee who provides information, who causes information to be provided or who otherwise assists in an Investigation.
  • Seize dealing with the service provider in any form.

Anyone who suspects to have been, or who in fact has the Retaliated against in violation of this rule must report this immediately to the Reporting Officer. The Reporting Officer must consult with BARCC.

4th Maintain Confidentiality

  • The Reporting Officer and all other Authorized Persons must protect the Whistleblower’s identity and other details of the Concern, as well as the details of an Investigation, by sharing this information only with other Authorized Persons and only on a strict ´need to know´ basis.
  • An exception to the Confidentiality principle is when EDB is legally required by applicable laws or regulations to disclose information related to a Whistleblower´s Concern, including the Whistleblower’s identity and/or the identity of the accused person(s), to an external party who is legitimately authorized. This would be the case for example when EDB must obey to court orders, or reporting obligations to public authorities such as regulators, the police, and the local department of.
  • Another exception to the Confidentiality principle is when the disclosure of such information is necessary when EDB decides to report to relevant regulatory or criminal authorities.


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