Whistleblowing

The following people may make a whistleblowing report and are protected under the Whistleblowing Law:

• Persons working in the private sector and who have information about violations obtained in a professional context, including at least:
  • Persons with the status of employee or self-employed person.
  • Shareholders and members of the management or the Board of Directors, including non-executive members;
  • Volunteers and paid or unpaid trainees;
  • Contractors, subcontractors and suppliers.

• Persons whose employment relationship has since been terminated or has not yet started (applicants) and insofar as the information about violations was obtained during the hiring process or other pre-contractual negotiations.

• Persons who pass on information obtained outside a professional context, insofar as it is a violation in the field of financial services, products and markets or any violations against it in the area of ​​preventing money laundering and terrorist financing.

The following persons are equally protected under the Whistleblowing Law:

• Facilitators (persons who assist the whistleblower in the reporting process and whose assistance should be confidential).
• Third parties associated with the whistleblower and who are at risk of retaliation in a professional context (such as colleagues or relatives of the whistleblower).
• Legal entities owned by or associated in a work-related context with the whistleblowers.
• Whistleblowers who pass on information obtained outside a work-related context, insofar as it is a violation in the field of financial services, products and markets or any violation in the area of preventing money laundering and terrorist financing.

A person can report a serious concern about suspected or actual criminal conduct, unethical conduct or any other misconduct relating to any of the following, although this is not an exhaustive list:

• Public tenders.
• Financial services, products and markets, avoidance of money laundering and terrorism financing.
• Consumer protection.
• Protection of private life, data protection, protection of network and information systems.
• Tax fraud
• Social fraud
• Criminal offences.
• Any failure to comply with a legal obligation.
• Miscarriages of justice.
• Threats to, or harm caused to, people’s health and safety.
• Threats to, or harm caused to, the environment.
• Attempts to conceal any of the above matters.

All whistleblowing reports will be dealt with confidentially. This means that the identity of the whistleblower cannot be disclosed to persons other than the Whistleblowing Officer, without his or her free and explicit consent. This also applies to all other information from which the identity of the whistleblower can be derived directly or indirectly.

Whistleblowers who make whistleblowing reports in a reasonable belief that an issue covered by the applicable legislation has occurred, is occurring or will occur, even if they turn out to be mistaken must not be threatened, retaliated against, harassed or bullied in any way.

Within Lloyd’s Europe the Compliance Department will take up the role of Whistleblowing Office.

As an independent control function, the Compliance Department can be considered as independent and free from any conflicts of interest.

Whistleblowing reports can be made to the following e-mail address: LloydsEurope.Whistleblowing@lloyds.com

The helpline is available to the company’s employees, contractors and consultants and staff employed by other Lloyd’s entities. It can also be used by those who were previously in such roles, for example, former employees and former contractors.

The whistleblowing helpline is operated by an independent, third party organisation called Safecall. It is a completely confidential service and whistleblowing reports can be made anonymously if the whistleblower wishes to do so.

Telephone:

www.safecall.co.uk/report

A whistleblowing report may be submitted to the National Bank of Belgium (NBB) or Financial Services and Markets Authority (FSMA) regarding matters within their respective areas of supervision. The NBB supervises prudential matters and the FSMA supervises conduct of business areas.

National Bank of Belgium (NBB)

The NBB’s contact details for the department of Insurance Supervision are as follows:

National Bank of Belgium
Boulevard de Berlaimont 14
1000 Brussels
Belgium

Telephone: +32 2 221 27 31
Email: insurance.supervision@nbb.be
Website: www.nbb.be/en/financial-oversight/general/report-breach

Financial Services & Markets Authority (FSMA)

The FSMA’s contact details are as follows:

Investigations Officer, Confidential – LAK2392
Investigations Officer
Enforcement Department
Financial Services and Markets Authority
Rue du Congrès 12
1000 Brussels
Belgium

Telephone: + 32 2 220 56 66
Website:

www.fsma.be/en/faq/whistleblowers-point-contact (English)

www.fsma.be/fr/faq/point-de-contact-lanceurs-dalerte (French)

www.fsma.be/nl/faq/contactpunt-klokkenluiders (Dutch)

The website above contains information about how a whistleblowing report can be submitted, how it will be handled by the FSMA and the protection that the FSMA will give to the whistleblower. Whistleblowing reports can be made to the FSMA anonymously if the whistleblower wishes to do so.

Whistleblowing reports can be submitted to the FSMA online in French or Dutch via the links below.

https://whistleblowing.fsma.be/fr/ (French)
https://whistleblowing.fsma.be/nl (Dutch)

An appointment for a face to face meeting with the FSMA to report or discuss a whistleblowing matter can be made via the links on its website above or by telephoning the number above. Telephone calls to this number are not recorded.

Federal Ombudsman

The Federal Ombudsman has the role of Federal Coordinator of external whistleblowing reporting in the private sector.

In this role, the Federal Ombudsman can be contacted with whistleblowing reports related to the financial services sector by the protected persons under the Belgian Whistleblowing Law.

The Federal Ombudsman’s contact details for the filling of whistleblowing reports are as follows:

–              Online whistleblower reporting form:

https://www.federaalombudsman.be/en/whistleblower-reporting-form

–              E-mail:

Send an e-mail to: integrity@federalombudsman.be

–              By appointment:

Send an e-mail to: integrity@federalombudsman.be  or call 0800 999 61 or +32 (0)2 289 27 27 to make an appointment with a member of the Integrity Centre.