Whistleblowing
How to raise a concern, including anonymously, outside the management chain.
If you believe something at Terravek is seriously wrong, we would rather hear it than not. This channel reports to the Chair of the Audit Committee and bypasses management entirely, including the Executive Board.
Who can use it
Anyone. Employees, contractors, interns, supplier and partner staff, customers, and members of the public. You do not need to be able to prove your concern — a reasonable belief is enough.
What it is for
- Breach of law or regulation
- Fraud, bribery, corruption or financial misstatement
- Danger to health, safety or the environment
- Breach of our dual-use policy or misuse of our products
- Serious breach of the Code of Conduct, including harassment and discrimination
- Deliberate concealment of any of the above
It is not the route for ordinary grievances, performance disputes or customer complaints — those go to hr@terravek.com or support@terravek.com and will be dealt with properly there.
How to raise a concern
| Route | Detail | Anonymous? |
|---|---|---|
| Independent reporting line | Operated by an external provider. Web and telephone, 24/7, in Dutch, English, German, French, Estonian and Swahili. Details are posted in every office and on the intranet; non-employees can request them from legal@terravek.com. | Yes |
| Chair of the Audit Committee | Dr. Nadia El-Amrani, in writing via board@terravek.com marked Confidential — Audit Committee Chair. Company Secretary forwards unopened. | If you choose |
| Data Protection Officer | dpo@terravek.com — for concerns specifically about personal data. Independent of management. | If you choose |
| External authority | You may go directly to a competent authority — in the Netherlands, the Huis voor Klokkenluiders. You are not required to come to us first. | Per that authority |
What happens next
- Acknowledgement within seven days, where you have given us a way to reach you.
- An initial assessment by the Audit Committee Chair, who decides who investigates. Nobody implicated in a report has any role in handling it.
- Feedback within three months on the outcome, to the extent we lawfully can.
- An anonymised summary of the number and category of reports goes to the Supervisory Board annually and is summarised in the sustainability report.
Protection from retaliation
Retaliation against anyone who raises a concern in good faith is a disciplinary matter up to and including dismissal, and this applies regardless of whether the concern turns out to be well founded. This is not a formality: it is the single thing that determines whether a channel like this is used at all.
Terravek complies with the EU Whistleblower Directive (2019/1937) as implemented in Dutch law and equivalent provisions in each jurisdiction where we operate.
Policy owner: Dr. Nadia El-Amrani, Chair of the Audit Committee. Administered by Owen Radcliffe, Company Secretary. Reviewed September 2025.
Last revised 30 September 2025. Questions: legal@terravek.com