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Whistleblowing

Whistleblowing policy and reporting channel

ERAM Group operates an independent confidential whistleblowing channel for employees, contractors, suppliers, customers, and third parties. Consistent with the EU Whistleblower Directive (EU 2019/1937) and Kosovo Law 06/L-085 on the Protection of Whistleblowers.

Draft template — legal counsel review required. This page is a structural draft prepared to the framework of GDPR (Regulation EU 2016/679), the EU Whistleblower Directive (2019/1937) where relevant, and applicable Kosovo law. It is not legal advice. Final text must be reviewed and approved by qualified legal counsel before publication.

1. What can be reported

The whistleblowing channel is open for good-faith reports of suspected misconduct including:

  • Bribery and corruption.
  • Fraud, financial misreporting, or theft.
  • Modern slavery, forced labour, or human trafficking in operations or supply chain.
  • Serious breaches of health, safety, or environmental law.
  • Breaches of data protection law.
  • Anti-competitive practices.
  • Discrimination, harassment, or retaliation.
  • Concealment or attempted concealment of any of the above.

2. Who can report

The channel is open to all employees and former employees, contractors, suppliers, customers, business partners, candidates, and any other person with a work-related relationship to ERAM Group.

3. How to report

Reports can be submitted through any of the following channels:

  • Email: whistleblowing@eram-group.net. This inbox is monitored by an independent Compliance Officer.
  • Postal: Confidential, addressed to the Compliance Officer, ERAM Group Ltd., Str. Bajram Gashi, no. 212, 14000 Lipjan, Republic of Kosovo.
  • External channel: Reports can also be made to the competent Kosovo authorities under Law 06/L-085 and to EU institutions under the channels established by Directive EU 2019/1937 where applicable.

Reports can be submitted in Albanian, Serbian, or English. Anonymous reports are accepted and investigated where the information is sufficient.

4. Confidentiality

The identity of the reporting person is protected. Access to reports is restricted to the Compliance Officer and to persons specifically authorised to investigate or to act on the report. Disclosure of identity outside this restricted group requires the consent of the reporting person, except where disclosure is mandatory under law.

5. Protection from retaliation

Retaliation against a person making a good-faith report is expressly prohibited. Forms of retaliation that are prohibited include dismissal, suspension, demotion, reassignment, harassment, withholding of training, withholding of references, and adverse changes to contractual terms. Retaliation is grounds for disciplinary action up to and including dismissal.

6. Process and timeline

  • Acknowledgement of receipt: within seven calendar days.
  • Feedback on the outcome of the assessment or investigation: within three months of acknowledgement (Article 9(1)(f) of Directive EU 2019/1937).
  • Where the timeline cannot be met, the reporting person is informed in writing of the reason and given a revised timeline.

7. Reports made in bad faith

The protections in this policy apply to reports made in good faith. Reports made knowing the information to be false, with the intention of damaging the reputation of the person reported on, are not protected and may be the subject of disciplinary action.

8. Records

Records of reports and investigations are retained in accordance with the requirements of Directive EU 2019/1937 and Kosovo Law 06/L-085, and in accordance with our data protection policy.