← Speak up

Whistleblowing channel

Speak-up policy

Version 1.0Effective 22.10.2026Owner: Jens Verhiest (COO)

1. Why this policy

Karomia wants problems to come out early, so we can fix them. This policy explains how anyone can report a suspected breach safely, what we do with a report, and how we protect the people involved.

Karomia has fewer than 50 employees and is not legally required to run an internal reporting channel. We chose to set one up anyway and to follow the standards of the EU Whistleblower Directive (2019/1937) and the Belgian Act of 28 November 2022 as a matter of company policy.

2. Who can report

Anyone who learns about a possible breach through their work with Karomia, including:

  • employees, former employees, interns, students and job applicants
  • freelancers, contractors and their staff
  • shareholders, directors and board members
  • customers, suppliers, partners and their staff

3. What you can report

Suspected breaches, past, ongoing or likely to happen, in these areas:

  • fraud, corruption, bribery or other financial misconduct
  • tax fraud and social security fraud
  • privacy, data protection and the security of networks and information systems
  • product safety, environmental protection, public health and consumer protection
  • competition law, public procurement and anti-money laundering
  • any other breach of Belgian or EU law
  • serious breaches of Karomia policies, such as the HR policy or our information security policies

You do not need proof. A reasonable suspicion, based on facts you know, is enough.

Not covered by this channel:

  • Harassment, violence and other psychosocial risks at work: these follow the procedure under the Welfare at Work Act. Karomia does not work with an external prevention service; contact Jens Verhiest (COO) or, if the situation involves him, Luc Machiels (CEO).
  • Personal disagreements about your own employment terms (pay, schedule, evaluation): talk to your manager or Jens.

4. How to report

Choose the channel that suits you:

  • Online form: karomia.eu/speak-up. Can be used anonymously.
  • Email: jens.verhiest@karomia.eu, subject "Speak-up"
  • In person or by phone: ask Jens for a meeting. We will meet within 14 days and, with your consent, write a summary that you can check and correct.
  • By post: Karomia BV, Attn. Reporting manager, "Confidential", Gaverlandstraat 62, 9031 Gent

If your report concerns Jens Verhiest, report to Luc Machiels (CEO), luc.machiels@karomia.eu. If it concerns both founders, report to Ruth Janssens (board member), ruth.janssens@imecistartfuturefund.com. The person concerned is then excluded from handling the report.

Anonymous reports are accepted and followed up. Without any way to reach you we cannot confirm receipt or ask questions, so consider creating a separate email address for this.

5. Who handles reports

RolePersonHandles
Reporting managerJens Verhiest, COOAll reports, unless they concern him
AlternateLuc Machiels, CEOReports about Jens, or when Jens is absent or conflicted
EscalationRuth Janssens (board member)Reports about both founders

The handler acts independently and has no conflict of interest in the report. Anyone with a possible conflict steps aside. For complex or sensitive matters the handler may involve an external lawyer, who is bound by professional secrecy.

6. What happens after you report

  1. Acknowledgement within 7 days of receipt.
  2. Assessment: is the report in scope and is there enough information to act on? We may ask you questions.
  3. Follow-up: an internal investigation or other appropriate action, carried out confidentially and fairly. The people concerned get the chance to give their side.
  4. Feedback within 3 months of the acknowledgement, on the action taken or planned and the reasons. We share what we can without harming the investigation or other people's rights.
  5. Closure: the report is closed and the outcome recorded in the register.

7. Confidentiality

Your identity, and anything that could identify you, is only known to the handler. It is not shared with anyone else without your explicit consent, unless the law requires it (for example in judicial proceedings). In that case we inform you first, unless that would harm the investigation.

The identity of people named in a report is protected in the same way.

Reports are kept in a restricted mailbox folder and register that only the handlers can access. In a small team it can be hard to stay fully anonymous, so describe the facts without details that point to you if you want to stay unknown.

8. Protection against retaliation

Karomia does not tolerate retaliation against anyone who reports in good faith, or against people who help them, such as colleagues or family members. Retaliation includes dismissal, demotion, a negative evaluation, loss of a bonus or warrants, a change of duties, intimidation and exclusion, and also the threat of any of these.

Anyone who retaliates, or tries to stop someone from reporting, faces disciplinary action up to dismissal. If you believe you are being retaliated against, report it through the same channels.

Reporting in good faith means you had reasonable grounds to believe the information was true when you reported it, even if it later proves wrong. Knowingly false reports are not protected and may lead to disciplinary action.

9. Reporting to the authorities

You can always report directly to the authorities, without reporting internally first. The Federal Ombudsman is the federal coordinator for whistleblower reports in the private sector: federaalombudsman.be. Depending on the subject, other authorities can be competent, such as the Data Protection Authority, the FSMA or the tax and social inspection services. We encourage internal reporting first so we can act quickly, but the choice is yours.

10. Privacy notice

  • Controller: Karomia BV, Gaverlandstraat 62, 9031 Gent, BE 1004.945.239.
  • Purpose: receiving, investigating and following up reports, and protecting reporters and the people concerned.
  • Legal basis: Karomia's legitimate interest in detecting and stopping breaches (art. 6.1.f GDPR), and legal obligations where they apply.
  • Data: what you choose to share, and data about people named in the report. Only data needed for the report is processed; data that is clearly irrelevant is deleted.
  • Access: the handlers only, and an external lawyer or authority where needed.
  • Retention: as long as needed to handle the report and any related proceedings. Closed reports are deleted or anonymised within 2 years after closure, unless proceedings are ongoing.
  • Your rights: access, correction, deletion, restriction and objection, by contacting the data protection officer. These rights may be limited where needed to protect the confidentiality of a reporter or an investigation. You can lodge a complaint with the Data Protection Authority (gegevensbeschermingsautoriteit.be).
  • Data protection officer: Jens Verhiest. For data protection questions about a report that concerns Jens, contact Luc Machiels.

Ready to report?

Use the online form. You can stay anonymous.

Go to the speak-up form