Integrity policy

Integrity is about both moral integrity and financial integrity. Moral integrity is about the absence of things like harassment, transgressive behaviour, discrimination, abuse of power and conflicts of interest. Financial integrity is about the responsible acquisition and use of resources, absence of fraud and corruption, etc.

Solidagro works on its integrity by pursuing consistency and transparency at all levels of the organisation. We strive to be equal and fair in relation to others and the environment. An integrity policy based on a dynamic integrity charter (see below) reminds us of our responsibilities.

Integrity charter

In 2018, Solidagro signed an integrity charter that includes 10 concrete actions to prevent integrity violations as much as possible and, if a violation does occur, to detect it and deal with it appropriately. You can find the integrity charter and its accompanying actions here.

Integrity officer Tim De Roeck, integrity adviser Elisa Tondeleir and complaints manager Paul Verbeke coordinate the implementation of the charter. In consultation with employees, they formulate appropriate measures and action points.

Roles and responsibilities of our integrity policy

The integrity officer is Tim De Roeck, director of Solidagro. He is responsible for giving shape to the points of the integrity charter. This consists of establishing and maintaining a true culture of integrity within the organisation by, among other things, identifying areas for improvement and drawing up an action plan.

The integrity counsellor is Elisa Tondeleir, Solidagro's policy officer. The integrity counsellor should be the person to whom any employee or volunteer in the organisation can turn in confidence for advice on integrity. She supports by reflecting, if desired, on possible follow-up steps and actions, with active listening being central. The integrity adviser is bound by confidentiality, unless there is an exceptional situation (such as a serious and imminent danger to a person or the organisation) that cannot be avoided without breaching that confidentiality.

The complaints manager is Paul Verbeke, president of Solidagro. The complaints manager adequately follows up integrity complaints submitted through the confidential hotline. The complaints manager reviews and analyses these integrity complaints and does so as independently and confidentially as possible. Based on this analysis, the complaints manager proposes measures, actions and possibly sanctions.

More info can be found here.

What happens to my complaint?

0. Informal reporting

You can discuss your suspicion of an integrity violation confidentially with a staff member, the integrity complaints manager, the integrity officer, the integrity advisor or a board member at any time. They can inform and guide you trough the formal reporting procedure if you wish. The comprehensive complaints handling procedure can be found here.

1. Confidential hotline

Before a formal report or complaint is submitted, an informal report is possible. A reporter can at any time confidentially discuss his/her suspicion of a violation with a staff member, manager, director, complaints manager, the integrity adviser or board member. They can inform and guide the reporter through the formal reporting procedure if desired.

Through our first-line hotline, you can formally file an integrity complaint. This complaint concerns something you have experienced yourself or something you have seen that violates our code of conduct.

Through this procedure, a complaint or notification is admissible if:

it relates to breaches of integrity committed by Solidagro, including its directors, employees and volunteers in the performance of their duties.
the complaint or notification was made by an interested party, such as every employee, director, partner and beneficiary of Solidagro.
the facts of the complaint took place no more than 10 years ago.
the complaint or notification was made via Solidagro's first-line hotline.
the complaint was not filed anonymously.
it does not concern a complaint or report that was previously made and to which adequate action was taken.

The hotline is back here. The report will then reach our complaints manager (Paul Verbeke) and our external consultant (Birgit De Clerck).

2. Receipt confirmation

After receiving the complaint or notification, the complaints manager sends an acknowledgement of receipt to the reporter.

3. The preliminary investigation

The preliminary investigation is conducted by Paul Verbeke, the complaints manager and president of Solidagro. Through the preliminary investigation, the complaints manager determines whether an investigation should be conducted following a report and assesses the admissibility of the complaint or report.

The complaints manager prepares a report of the preliminary investigation. Based on his findings, in connection with the admissibility assessment, the genuineness and provability of the alleged facts, the complaints manager makes a proposal of an investigation or not.

The complaints manager always carries out an independent analysis and provides timely feedback to the reporter. If necessary, he will check with the integrity officer (Tim De Roeck) or members of the board, but only after agreement with the reporter. The integrity counsellor (Elisa Tondeleir) is not informed about the preliminary investigation or the investigation of the complaint or report.

If the preliminary investigation shows that there are no grounds for an investigation, the complaints manager informs the complainant with a brief justification.

4. The study

Based on the facts and data of the investigation, it is decided which persons will be involved and whether the investigation will be conducted internally or externally. Discretion and confidentiality are guaranteed to the maximum.

The complaints manager always applies the following principles:

confidentiality of information;
proportionality;
treatment within a reasonable time;
absence of bias;
protection of the parties involved.

The facts, sensitivity, risk and complexity of the complaint or report are always assessed against these principles. The complaints manager always takes an independent, confidential and respectful position towards all parties involved.

Deviations from keeping the reporter's identity confidential can only be made with the express consent of the parties involved or when required by law.

5. Handling and follow-up of the investigation

If the investigation shows that possible criminal offences were committed, advice may be sought from an internal or external expert, after which judicial authorities will possibly be seized. If the investigation shows no integrity violation was committed, no measure will be imposed.

Appropriate measures are taken towards the offender. These obviously depend on the investigation and can vary widely. Appropriate measures include a reprimand or warning, immediate dismissal, mediation or amicable settlement.

Determining the sanction is done by the complaints manager, possibly after internal or external advice.

The outcome of the complaint investigation shall be communicated to the reporter and, if applicable, the victim of the violation. Reasonable time must be respected for this purpose. The exact form of follow-up towards the victim depends on the facts, circumstances and the outcome of the investigation. In any case, the complaints manager keeps a finger on the pulse after the complaint procedure has been completed.