Whistleblowing report related to violations of law or internal regulations
At Colonnade, we care about compliance with law and ethical business conduct. Therefore, we provide the opportunity to report any improper conduct violating laws or internal regulations committed by any person in the work-based relationship with Colonnade Insurance S.A.
When can you make a report?
If you have any substantiated grounds or information to believe that an actual or potential breach of the law or grossly unethical and improper behavior has occurred or is likely to occur in respect of Colonnade's activities. Your report will be treated in full confidence and in such a way which is safe for you.
Who can make a report?
Any person may be a whistleblower if he is:
· an employee of Colonnade or a former one,
· a person applying for an employment with Colonnade,
· a person in the work-based relationship different from an employment contract,
· an entrepreneur in commercial relationship with Colonnade,
· a Colonnade´s shareholder or partner,
· a member of any Colonnade´s body if different from an employee,
· any person performing the work for Colonnade under the supervision or direction of a contractor,
· a subcontractor or supplier of Colonnade,
· a Colonnade´s trainee or volunteer.
Designated Officers for internal reporting channel
Reporting persons may submit their reports to Colonnade Head of Compliance or, in the absence of the latter, to Colonnade Chief Risk Officer, who are appointed by the Board of Directors as persons designated.
How is a person making the notification protected?
Reporting persons must not be subject to any form of retaliation, threats or attempts to use them and are legally protected. Colonnade guarantees the full confidentiality of the data provided in the notification and protects the identity of the reporting person, person concerned as well as the third persons referred to in the report.
The internal report done – what then?
A person making the report will receive an acknowledgement of it receipt within 7 days following its submission and a feedback and follow-up measures taken by Colonnade within 3 subsequent months (unless the report is made anonymously in such a way not enabling to Colonnade to identify the address of the person making the notification).
How can the internal report be made?
The report can be made through one of the following communication channels:
- by e-mail to: whistleblowing@colonnade-insurance.com
- by standard mail marked "Whistleblowing-confidential!" to:Colonnade Insurance S.A. 1b, rue Jean Piret, L-2350 Luxembourg, Luxembourg
- by phone on the following numbers: +352 281156-204 (Head of Compliance Colonnade) or +352281156-206 (Head of Risk Management Colonnade)
- in person, at the request of the whistleblower, either directly or using the intermediation of the local Compliance Officers and Risk Management Managers.
In the case of an e-mail and postal notifications, these may also be made in an anonymous form!
Please note that this internal communication channel is not intended for complaints (petitions)!
Petitions regarding an insurance policy or any of our services must follow the procedure detailed on the website in the section Make a complaint | Colonnade Insurance S.A.
External reporting (to authorities)
The report shall be made directly through external reporting channels, where the whistleblower considers that there is a risk of retaliation and that the breach reported cannot be effectively addressed through internal channels reporting. The authorities competent to receive reports on breaches of law are public authorities and institutions which, according to special legal provisions, receive and resolve reports on breaches of law, in their field of competence; National Integrity Agency; other public authorities and institutions to which the Agency delegates its competence to deal with reports.
Public disclosure
A whistleblower who publicly discloses information on breaches of law shall qualify for protection if one of the following conditions is met:
a) first reported internally and externally or directly externally, but considers that appropriate measures were not ordered within the legal deadline;
(b) has reasonable grounds to believe that:
1. the infringement may constitute an imminent or manifest danger to the public interest or a risk of damage which can no longer be remedied; or
2. In the case of external reporting, there is a risk of retaliation or a low probability that the breach will be effectively remedied given the specific circumstances of the report.
The notification regarding the violation of the law by public disclosure may be addressed to the press, professional, trade union or employers' organizations, non-governmental organizations, parliamentary committees or by making available in any way in the public space information regarding violations of the law.