Whistleblowing Policy
Image of various Glacier products and ingredients.

1. Purpose 
Glacier is committed to conducting its business in accordance with all applicable laws, rules and regulations and the highest ethical standards. This commitment and these requirements apply both internally to our employees and externally when collaborating with customers, suppliers and third parties.

Glacier wishes to preserve and promote a culture, characterised by its ethical values and principles, including honesty and transparency. It is therefore our common responsibility to report any facts that could be detrimental to Glacier.

This shall be done in a way that assures everyone that these reports can be made without facing any risk of retaliation and with the guarantee of a fair and confidential investigation.

To fully facilitate this, a whistleblowing scheme is implemented, in addition to existing operational and internal control procedures, to detect and limit breaches falling within the scope of the Whistleblowing Act.

2. Definitions
For the interpretation, assessment and application of the Policy, the following expressions have the below meaning, unless the context requires otherwise:

  • Breach: an act or omission that directly violates or contradicts the purpose or application of the rules within the material scope of the Whistleblowing Act, namely:
    • any breach of legal or regulatory (enforcement) provisions relating to: 
      • public procurement; 
      • financial services, products and markets and prevention of money laundering and terrorist financing; 
      • product safety and conformity; 
      • transport safety; 
      • environmental protection; 
      • radiation protection and nuclear safety; 
      • food and feed safety, animal health and welfare; 
      • public health; 
      • consumer protection; 
      • protection of privacy and personal data, and security of networks and information systems; 
      • tax fraud; 
      • social fraud; 
      • food safety & quality such as contamination, mis‑labelling, falsified records, product safety risk; 
      • health & safety/worker welfare such as unsafe practices, serious risk of injury.  
    • breaches affecting the financial interests of the European Union; 
    • breaches relating to the internal market, including breaches of Union competition and State aid rules, as well as breaches relating to the internal market in relation to acts which breach the rules of corporate tax or to arrangements with the purpose of obtaining a tax advantage that defeats the object or purpose of the applicable corporate tax law.
  • External Reporting: the communication of information on Breaches to the competent authorities or public authorities, and thus not via the Reporting Channel. 
  • Good faith: the Whistleblower has reasonable grounds to believe that a potential Breach exists, supported by facts and data.  
  • Glacier Group Whistleblowing Office: the Whistleblowing Officer(s) responsible for handling reports made through the Reporting Channel. 
  • Internal Reporting: reporting information about Breaches within Glacier through the Reporting Channel. 
  • Policy: the present regulation that lays down the terms and conditions of the whistleblower scheme. 
  • Protection: all required measures enforced by Glacier to maintain the confidentiality of the Whistleblower’s identity and his/her report. It also includes all measures to be taken to safeguard the Whistleblower from any form of Retaliation in the framework of the Whistleblowing Directive. 
  • Public Disclosure: the public release of information about Breaches. 
  • Retaliation: any direct or indirect act or omission which occurs as a result of an Internal or External Reporting or Public Disclosure, and which causes or may cause unjustified harm to the Whistleblower. 
  • Whistleblower: natural person who reports or publicly discloses information on a (potential) Breach obtained in a Work-related Context, included in the list in section 3.1. 
  • Whistleblowing Directive: the Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law. 
  • Whistleblowing Act: the Act of 28 November 2022 on the protection of persons who report breaches of Union or national law, or applicable national laws implementing the EU Whistleblowing Directive within a legal entity in the private sector. 
  • Whistleblowing: the reporting in Good Faith (either Internally or Externally) of a (potential) Breach. 
  • Whistleblowing Officer(s): the team responsible for receiving and monitoring Whistleblowing reports made under the Policy.  
  • Work-related Context: as defined by the EU Whistleblowing Directive, means current or past work activities within Glacier, regardless of the nature of those activities, through which persons acquire information about Breaches and in which those persons could be subject to Retaliation if they reported such information. 
3. Scope of the Policy
3.1. In scope

The Policy applies to all persons who, in good faith, report a Breach after acquiring information in a Work-related Context. Such persons include, but are not limited to:

  • Glacier employees, persons holding powers of daily management and self-employed directors; 
  • Glacier contractors, consultants, service providers, suppliers and business partners; 
  • Shareholders and any other person occupying executive, managerial and/or administrative positions within Glacier. This also includes non-executive members of Glacier, voluntary workers and interns, regardless of their remuneration. 

The Policy is not only applicable to Whistleblowers with an ongoing relationship with Glacier, but also applies to all persons who (i) report Breaches that occurred during a relationship that has already ended; or (ii) has not started yet (e.g., as a result of information obtained during a recruitment phase). 

Also taken into account:

  • “facilitators”, being natural persons who support a Whistleblower in reporting an alleged Breach; 
  • any third party, like colleagues and relatives, connected to the Whistleblower that could face any form of Retaliation; 
  • any legal entity to whom the Whistleblower is connected.
 

3.2. Out of scope
The purpose of the Policy is not to oppose Glacier business and/or financial decisions nor is it intended to assess elements that are the subject of other specific policies, regulations or procedures. Such matters may be handled under other policies but can still be reported through this channel.

4. Reporting process
4.1. When to report?
The Whistleblower must act in good faith.

It is important that the concerns raised are genuine and not based on gossip or rumours. Alleging improper behaviour on the part of another person can be damaging to that person and others, so it is important that any allegations can be supported with sufficient information.

4.2. What to report?
All Breaches, as defined in section 2, can be reported.

4.3. How to report?
4.3.1. Internal Reporting
You can use any of the following channels. You do not need to use them in order. Choose the one you trust:

  1. Secure online portal (anonymous enabled)
  2. In‑person meeting 
    • Request a meeting with your site People Business Partner. We will offer a meeting within a reasonable timeframe and can arrange an off‑site or virtual option if you prefer.
The online portal is configured to accept anonymous reports. If you choose to remain anonymous, please keep your case ID safe so we can communicate with you.  4.3.2. External Reporting and Public Disclosure  Whistleblowers can still benefit from Protection when they publicly disclose Breaches if they comply with the below requirements, implying that Public Disclosure should be the last resort. A person who makes a public disclosure shall only qualify for Protection if either of the following conditions is met: 
  • the person first reported Internally and Externally, or directly Externally, but no appropriate action was taken in response to the report within a reasonable timeframe; or 
  • the person has reasonable grounds to believe that the Breach may constitute an imminent or manifest danger to the public interest.
If a Whistleblower chooses (following an Internal Report) to report through the external reporting channel, he/she may contact: 
  • Italy: National Anti‑Corruption Authority (ANAC) external channel. 
  • France: Designated authorities (per Sapin II/Waserman) or competent EU bodies; public disclosure allowed in defined cases. 
  • Belgium: Federal Ombudsman external channel (private sector whistleblowing). 
  • United Kingdom: Report to prescribed persons/regulators under PIDA (see GOV.UK list).

4.4. Investigation of reportsGlacier guarantees to all Whistleblowers that all Internal Reports made in good faith under the Policy will be thoroughly and impartially investigated. The following steps are performed: 
  • A Whistleblowing Officer will acknowledge having received the report by notifying the Whistleblower within 7 days of receipt; 
  • A Whistleblowing Officer will do an initial assessment to confirm it is a valid report within the scope of the Policy; 
  • A Whistleblowing Officer will start the investigation; 
  • A Whistleblowing Officer will follow up on the reports and provide feedback to the Whistleblower. He/she will request additional information from the Whistleblower if necessary and possible; 
  • The final outcome of the investigation will be shared with the Whistleblower no later than three months after receipt of the report. The content and scope of this feedback will be determined on a case-by-case basis, to the extent that sharing such information is allowed and relevant; 
  • Where appropriate, the information will be shared by the Whistleblowing Officer with the competent authorities or public authorities in due time. 

In case the Breach is proven, Glacier assures that appropriate and proportionate measures are taken (e.g., disciplinary measures, dismissal and/or legal proceedings). Furthermore, Glacier strives to implement the necessary steps to prevent, as far as possible, further occurrences of such Breaches. 

5. Confidentiality & anonymity
Glacier aims to preserve the confidentiality of all Whistleblowers and any individuals who provide information during an investigation. When a Whistleblower chooses to identify themselves, their identity will only be accessible to the Whistleblowing Officers and will not be disclosed to anyone else unless the Whistleblower gives explicit consent, or disclosure is required by law. If disclosure becomes legally necessary as part of national authority investigations or judicial proceedings, the Whistleblower will be informed in advance unless doing so would compromise the investigation or related proceedings.

Whistleblowers may also choose to report anonymously. Glacier fully supports this option, and anonymous reports will be handled with the same care, confidentiality, and protection as identified reports. If a Whistleblower chooses to remain anonymous, they should retain their case reference number or login details so that we can continue communicating with them during the investigation.

While providing your identity can make it easier for us to:

  • conduct a thorough and efficient investigation, 
  • request clarification or additional information, and 
  • keep you informed of progress, 

there is no requirement to identify yourself, and choosing to remain anonymous will not affect your right to protection or how seriously your concern is treated. This confidentiality commitment also applies to any information that could directly or indirectly reveal a Whistleblower’s identity. 

6. Whistleblower Protection
In general, Retaliation or threats of Retaliation against individuals will not be tolerated or permitted under any circumstances. Examples of Retaliation include, but are not limited to, the following:

  • any form of adverse amendment to the employment;  
  • demotion;  
  • suspension;  
  • discipline;  
  • threats;  
  • intimidation;  
  • harassment.  
If an employee or party with whom Glacier has a business relationship is confronted with behaviour that he/she believes constitutes Retaliation, we ask that person to report it immediately through the Reporting Channel. Glacier will then investigate the Report and take appropriate action. For the reporting of Breaches, the Whistleblowing Directive imposes specific protection mechanisms: 
  • Where a Whistleblower reports information on a Breach in accordance with the Policy, they shall not be considered to have breached any restriction on disclosure of information and shall not incur liability of any kind in respect of such a report or disclosure provided that they had reasonable grounds to believe that the reporting or disclosure of such information was necessary for revealing a Breach. 
  • A Whistleblower reporting a Breach shall not incur liability in respect of the acquisition of or the access to the information, which is reported or disclosed, provided that such acquisition or access did not constitute a self-standing criminal offence. In the event of the acquisition or access constituting a criminal offence itself, criminal liability may be incurred based on applicable national law. 
  • In legal proceedings, including for defamation, breach of copyright, breach of secrecy, breach of data protection rules, disclosure of trade secrets, or for compensation claims based on private, public, or on collective labour law, Whistleblowers shall not incur liability of any kind as a result of reports of a Breach or Public Disclosures of a Breach. 
When reporting a Breach, Whistleblowers may also be entitled to: 
  1. legal aid in cross-border criminal and civil proceedings in accordance with the Whistleblowing Directive as well as legal assistance and advice, and other support measures that may be available under applicable law; 
  2. financial assistance and other support measures. 
Finally, it should be noted that even Whistleblowers who report Breaches are not safeguarded from remedial actions as a result of their own misconduct: 
  • If an employee makes a report, he or she may still be subject to prosecution based on facts unrelated to the report; 
  • The communication of false and/or misleading information in the context of an investigation into a Whistleblowing will not be tolerated; 
  • If the acquisition of or access to information used for the Whistleblower itself constitutes a criminal offence, it may lead to criminal prosecution. 

7. Protection measures for the persons concerned
Note that any person concerned by a report has the right to an effective remedy and to a fair trial, as well as to the presumption of innocence and the rights of defence, including the right to be heard and the right of access their file.

The identity of persons concerned is protected for as long as investigations triggered by the report or the Public Disclosure are ongoing.

The persons concerned in a report will also enjoy protection of their identity.

8. Consultation and communication
Where required by law, Glacier will consult employee representatives before implementing or materially changing internal reporting channels. We will also inform all workers about how to report and how their reports are handled.

9. Processing of personal data 
Any processing of personal data carried out in the context of a Whistleblower’s report, including the exchange or transfer of personal data by the competent authorities, shall be carried out in accordance with Regulation (EU) 2016/679 and Directive (EU) 2016/680, as well as the applicable Glacier Privacy Policies.

Personal data which are not relevant for the handling of a specific report will not be processed or, if processed accidentally, shall be deleted without undue delay.

Glacier collaborates with a third party subject to strict confidentiality and security standards for the Internal Reporting Channel and any investigation initiated, acting as a data processor under a data processing agreement with Glacier. Glacier remains the data controller. Your personal data will not be disclosed to or accessed by non-authorised staff members.