Standards of Business Conduct

recurv BV, hereafter “recurv” or “Recurv”, is committed to providing business excellence to all candidates, clients, and active consultants throughout all phases of recruitment and consultancy (R&C), from initial intake to placement and aftercare, to foster a long-term business partnership. We strive to deliver on the wants and needs of all business partners and go the extra mile to relieve them of every burden concerning filling or finding a job opportunity or project.

In doing so, we uphold a set of sectoral standards and ethical values we do not deviate from at any cost and undergo a case-by-case evaluation to transcend our quality of work. As a result, not only juniors but seniors and managers also keep an open mind for self-reflection, self-innovation and reskilling their knowledge by following the newest R&C trends, which enables them to bridge any knowledge gap and stay ahead of the curve.

At recurv, not only the recruiters but also those not involved with the core business are subject to delivering a carefree service to all candidates, clients and consultants. They are trained to work highly efficiently, providing quick answers to all questions and following up on all aspects and phases of R&C, be it legal, financial or customer related.

Hereunder, you will find a set of principles we promise to adhere to unconditionally:

1. As of the first contact, recurv shows the utmost professionalism, whereby the quality of service is the only measure used to qualify the standard of service.
2. All essential legal requirements are applied sine qua non. This guarantees risk-free business continuity, minimising any possibility for anyone to be held liable for any penal or civil shortcomings. If faults are observed, then recurv will, without any hesitation, inform the business partner of its shortcoming and cooperate in any way possible to maintain an uninterrupted flow of service provision. When recurv notices malintent from its business partner, it will take the necessary (legal) steps to safeguard the involved parties and itself from any resulting damages. For maximising business successes, creating opportunities for long-term strategic partnerships and expanding the scope of business, the legal department may weigh in on the cooperation modalities by applying stricter legal measures for as long as the legal basis is discretionary.
3. Given the nature of our business and the extensive time investments made in our clients’ HR-related needs, we ensure that the principles of non-discrimination, respect for personal privacy, and prevention and well-being of all business parties are strictly upheld and protected continuously.
4. Under no circumstances will recurv ask for compensation from a job-seeker or (active) consultant, not even if the former person in question remained jobless or had been provided with a job from another agency.
5. recurv can decline a job assignment unsuitable for its niche specialisation. However, it will remain open for business opportunities that might deviate from its usual partnerships for as long as business successes are guaranteed and offer a high return on (time)investment.
6. The recruiters, be they senior or junior sales or talent recruiters, have undergone lengthy and intensive training to provide a high-quality level of competence. Each of the recruiters has built up a unique network of consultants and or clients and will keep reskilling themselves to gear up on providing the right talent for future niche job positions. The business relationships they build with any party allow them to foresee and anticipate clients’ recruitment and business needs. This results in the immediate unburdening of the R&C needs by which the recruiters will provide thought-out candidates in the shortest possible timeframe. Whenever laws governing the business of R&C are changed, the management will inform the recruiters to stay ahead of any changes and inform the clients, candidates and active consultants of what might lay ahead regarding business continuity.
7. Transparency is considered a form of basic service but also a business necessity. However, only with the party’s permission and within the boundaries of applicable legislation will recurv provide the other party with the relevant information to create a soluble opportunity. Furthermore, in view of efficiency, we communicate fully and directly to prevent vagueness.
8. We ensure that all the information we have gathered about the candidates and active consultants is kept up-to-date, objective and clear. We will provide the collected information to the owners who have requested it without hesitation. Suppose a candidate or non-active consultant asks to delete their data. In that case, we will do so and respect the privacy of the person in question. If a request for correction is made, the recruiter will adjust the data as soon as possible.
9. Complaints are treated with the necessary attention and will be treated with complete objectivity. The complainant is guaranteed a well-grounded answer, and whenever a fault is observed on our behalf, the complaint is subject to rectification. A protest will never have adverse consequences for the disadvantaged party.
10. This quality charter is subject to change for as long as the change(s) made is not considered a deterioration of our business service. Furthermore, every employee of recurv will be informed of any changes made. In case of a status quo, a refresh will be offered yearly.

Should you wish to file a complaint, or if you have any questions regarding our Quality Charter or any of our Codes of Conduct, then our compliance officer will gladly help you via email at contact@recurv.be.

recurv ensures all parties of a personal and high-quality service tailored to the needs of our clients, candidates and active consultants. We keep following up on the market, anticipate future job opportunities and foresee relevant and qualitative human capital. However, given the nature of our business, the free market economy, the free will of all job-seekers to move at their own pace and changing financial policies of clients, the services we deliver must be constituted as an effort obligation for which we follow the definition of the Belgian civil code (art. 5.72 NBW). Considering the risks mentioned above, recurv grew into a uniquely successful consultancy and recruitment firm because of its many years of recruitment knowledge, bold, out-of-the-box thinking habits, and inventive and innovative ways to stay ahead of the competition. But with great success comes great responsibility, and therefore, as we lead by example, we have created a deontological code which sums up how we think, work and interact with all parties. These nineteen codes will offer insight into what to expect from working with us, whether you are a client, a candidate or an active consultant.

1. We build personal relationships with any party to ensure the best quality of service. In addition, we focus on long-term strategies to help companies and people reach their business successes.
2. We commit to being transparent in our way of working and guiding all parties throughout the phases of recruitment and selection. The candidates and or consultants have the right to know in detail what they are applying for and for which company.
3. We represent our candidates to our clients only with a formal consent containing detailed info on the opportunity or project.
4. We respect the privacy of all our clients, candidates and active consultants and practice caution when handling sensitive information. When data needs to be updated or removed, we do so with absolute diligence.
5. We follow up on the law and only accept criteria that do not violate local, national or international law.
6. We execute strict due diligence with all parties wanting to work with us. Whenever a conflict of interest arises, or we sense that an issue might emerge, the necessary steps will be taken to counter the threat by declining the service or altering the terms and agreements.
7. We make sure the job positions are suitable to our speciality. We only accept existing positions. We do a thorough analysis of the job content and job context so that we can deliver only the highest-valued candidates.
8. We assure continuous feedback on evaluating all candidates and ensure the latter is fully prepared to participate in the application procedure.
9. Except for project staffing, we inform every candidate that we are not responsible for hiring candidates. The actual recruitment is always done exclusively by the client. However, we challenge and ask for client feedback when a candidate is not accepted. In circumstances where our belief in the candidate is high, we will do our best to re-discuss the feedback with the client, and if necessary adding arguments and or additional reference checks.
10. We propose to our clients balanced and competitive terms and agreements where the emphasis is put on long-term business partnerships and ROI.
11. We ensure all parties of speedy and efficient customer service and remain continuously at everyone’s disposal.
12. We promise not to ask for references without the knowledge of the candidate.
13. We only ask the candidate and consultant questions about the job opening to guarantee a complete objective selection procedure free of prejudice.
14. We deviate from our objectivity criteria when we are legally subject to specific discriminatory metrics, including but not limited to, for example, job openings for the Defense Department.
15. We keep a professional distance from our candidates and consultants to ensure zero conflicts of interest for our customers.
16. We never recover costs from consultants and candidates. For both parties, the services we provide are completely free of charge.
17. We choose according to a first come, first serve principle for equally strong and equally qualified profiles when we have limited presentation slots for specific job opportunities.
18. We take into consideration all of the values laid out by the United Nations Global Compact to maximise our ethical values and norms during business dealings.
19. We comply unconditionally according to our self-written codes of conduct, which you can find further in this document. Even though we have written our regulations, we did base ourselves on the established rules of engagement but kept them relevant to our sector. We keep challenging ourselves to behave according to strict yet ethically approved rules where respect and dignity for each person are guaranteed.

As we follow strict, ethically justified actions, which our Quality Charter and Deontology ground, recurv does everything in its power to enforce ABC and maintain caution for red flags, potentially jeopardising long to short-term strategic partnerships. With this, we aim to work according to the highest ethical standards and norms and expect the same from our clients, candidates and active consultants. This policy also applies to the directors, executives and managers, all recruiters and back office employees, students and interns of recurv.

We firmly believe that our business success is not only based on our core business but also on the highest form of trust, goodwill and especially the transparency we guarantee to all parties we work with. We acknowledge that patience, transparency and due diligence outweigh any form of derogation for possible short-term gains. The penalties are not only financially severe, but the company’s image will be damaged beyond repair, licenses could be revoked, and jail time could be enforced according to art. 504bis and ter of the Belgian Penal Code. We strictly follow local and national law as well as international law and, to the extent applicable, the American Foreign Corrupt Practices Act and the British Bribery Act. Whenever we work with partners, clients and active consultants who have their registered office and or living in a foreign country, we respect and follow the legislation of that country.

With this ABC policy, we look for ways to better our business strategy and encourage competitors to join us. Hence, the recruitment and consultancy sector maintains a healthy, fruitful and competitively balanced playing field whereby everyone can deliver the best quality of work.

With this policy, we expect all parties to adopt the following approaches so bribery and corruption can be minimised:

• Transparency: Log every administrative action and keep a digital paper trail of every communication to protect yourself from being held liable. Keep in mind: if you cannot provide specific evidence or avoid any form of cooperation, you are automatically raising suspicion and increasing the chances of being held responsible for any violation with all its consequences;
• Responsibility: You and only you are responsible for the services you have provided. Make sure to immediately refrain from any suspicious actions and distance yourself from (possibly) corrupt correspondents. Raise the alarm bell at the earliest time possible.

If you break the law, you will bear the consequences, and recurv will do everything possible to halt the business cooperation and suspend the employment or service contract.

• Integrity: Be strong and vigilant. Whenever you suspect any form of wrongdoing, immediately inform your superior. Do not let possible short-term gains influence your behaviour, for only showing doubt results in reputational damage. It could also place you in a weak position as the offender could extort you;
• Honesty: Be honest and take pride in being sincere and truthful. This only raises your business potential and advances your career possibilities;
• Be commonsensical: Whenever payments for services are discussed or presented through disproportionate invoicing, you might be dealing with bribery. Keep asking yourself whether the amount to be paid or received corresponds with the delivered or received services. If questions arise, immediately ask your supervisor for help and do not take any actions until further notice.

Hereunder, you will find a more detailed policy outline on how to act accordingly in specific situations, how to spot ABC and what about it is prohibited and permitted. Nota bene: the ABC applies to everyone working for and with recurv, with no exceptions on seniority and business impact. Suppose sentences are written so that they could be understood to only apply to employees of recurv. The interpretation should be relevant to those working with recurv in that case. Not one party who is in communication (no matter the medium) with recurv, whether or not the exchange of services and money has already taken place, is excluded from this policy. Having taken the first approach to contact recurv or simply answering a first request for quotation (no matter the medium) with recurv means that you agree with all policies and refrain from violating them.

• Ban all forms of bribery and corruption: Do never accept services or material that holds value and vice versa, which creates the opportunity for corruption and bribery. Do not ignore any signs of violation of this policy, as this will automatically make you an accomplice, even if you do not benefit from the breach. Be especially vigilant when working with government officials and operating within the legal context of public procurement. Whenever the opportunity arises to work with the government, immediately discuss the potential business project with the legal department so due diligence can be performed. Do not hint at being open for bribery or corruption because recurv will unquestionably consider it to have committed the actual crime. This will immediately suspend your employment contract, business contract or any other form of contract, whether signed on paper or agreed on verbally.

The consequences mentioned in the previous sentence will automatically be applied to the violations of the policies outlined hereunder.

• Gifts and hospitality: Gifts and hospitality treatments are to be limited in value to a maximum of a hundred EURO (or the equivalent in the local valuta) and are only then ethically justified when the following criteria are cumulatively met:
  • They have legitimate and business-related purposes;
  • They are offered in the context of a typical business operation;
  • They are considered legitimate within the context of the local law;
  • The frequency per company to offer and or receive gifts and hospitalities is set once every quarter;
  • Apart from the cost, the following types of gifts and hospitalities are considered not done and will not be accepted, nor will they ever be sent out from recurv:
    • Cash or an equivalent such as but not limited to cheques, loans, securities… We only allow gift cards to be sent out from recurv which do not exceed the amount of 200 (two hundred) EURO and only within the context of a successful referral, for which the rules are laid out on the website;
    • Gifts or hospitalities that are improper, disproportionate to the services that have been or (possibly) will be delivered by or to recurv, and which violate the integrity and image of recurv;
    • Gifts or hospitalities which are offered during a public or private procurement process or in the context of a government or business-related decision-making process concerning procurement regulation;
    • Gifts and hospitalities which violate local, national and or international laws.

Suppose a conflict arises, and the supervisor has been informed about these irregularities. In that case, an in-house investigation will be set up to prevent escalation. In case of a legal offence, the justice department will be notified without hesitation.

Suppose the gifts and or hospitalities meet the condition described above. In that case, the person receiving them will only accept them for as long as the CEOs give their permission. Their permission is final, and they will monitor the person offering the gift or hospitality from that moment. Gifts or hospitalities are neither to be asked or demanded nor are part of a trade.

• Acceleration payment: All payments made in any form or shape, no matter the value and irrespective of time and date and whether done before, during or after a public procurement process or law-making procedure, are forbidden and will be considered a form of bribery. To cover up these payments and or to conceal them have equal punitive consequences as the one described above;
• Political contributions: recurv believes in respecting the established democratic processes concerning the creation of law and the implementation and execution of the law. It refrains from interfering with politics and avoids all forms of endorsements. Every form of action that is asked to be taken from a political party, no matter how small the contribution and irrespective of the cost, whether it exists in the form of a legal body or merely exists in the form of an unincorporated association, will be ignored and reported to the authorities;
• Corporate contribution to charities: When recurv finds the opportunity to contribute to a charity, it will only do so to recognised charities according to its liking. The grant will only be made upon unanimous approval of senior management of recurv on the amount and the type of charity. The charities should not interfere in the decision-making process, nor should they expect a guaranteed recurring contribution. The charity is not allowed to give something back in return except for recognition. The recognition, however, shall be costless. Furthermore, hereunder are several criteria which should be met cumulatively upon choosing the right charity:
  • The charity must be a registered non-profit entity;
  • The charity should enjoy tax-exempt status;
  • The charity should be completely free from government control. The persons receiving contributions from recurv on behalf of the charity should not be affiliated with a political party or political ideology whereby the ideology is actively or passively promoted on the media, in a closed or open public gathering, or by a government functionary;
  • The charity contributes to elevating the quality of life of underrepresented communities or people who suffer from a disease for which the procurement of medical treatments is financially impossible;
  • The contribution offered to the charity is solely meant for the core purpose and activity of that charity and is free from all forms of rewards or recompensations. All other intentions are to be considered non-existent. The person who contributed to the name of recurv will bear the consequence under the title “Ban on all forms of bribery and corruption“;
  • The contributions donated are not to be channelled to other charities or companies without the knowledge of recurv;
  • The contributions should be used for bonafide purposes only. These purposes should not be vague, whereby ethics and moral questions are raised or frowned upon;
  • The charity’s policies have to align with the guidelines laid out in this document. The rules laid out should in no way be less strictly regulated, nor should they be open for interpretation whereby actions taken by the charity are less ethically justified than those taken by recurv. The relevant policy guidelines should be as transparent, justifiable and controllable as the policies of recurv;
  • The contributions made by recurv should be carefully and in detail registered in the accounting without delay and separately recorded in a log;
  • Cash contributions or equivalents, such as but not limited to gift cards and loans, are prohibited.

The accounting department keeps track of every financial movement, whether money is coming in or going out. It ensures that no transaction is made without explicit instruction and permission given by the CEOs and supported by the supporting documents drawn up according to the law. Whenever large sums (+500 (five hundred) EURO) of money are transferred to beneficiaries outside recurv, the payment process is subject to the four eyes principle. All transfers are collected by the end of the month and double-checked by an independent accountant.

Retaliation against sources who spoke up against offenders is prohibited, and recurv will do everything possible to protect them. When necessary, they will involve the justice department to prevent risks. All sources are kept private, even if they wish to reveal their identity.

Typical red flags are summed up hereunder though it is to be considered non-exhaustive:

• Having an exceptionally good connection with a government employee, for which the latter coincidentally is involved in the cooperation between recurv and the government;
• Not willing to disclose basic due-diligence information during a request for quote phase;
• Is previously sentenced by any court in any country for infringements of any regulation concerning bribery or corruption and everything related to those criminal acts such as the ones described above and everything else that is related but not mentioned in this document;
• Having had an important cooperation agreement suspended without motivation;
• Having previously asked other companies to falsify invoices or different types of documents whereby an unauthorised advantage has been created;
• Refuses to promise in writing to follow any regulation concerning ABC;
• Asks for the over-invoicing or the partial payment to an unknown third party, whether it is cash or other types of untraceable funds;
• Charging fees and or provisions which are excessive, unfounded and or unfair in relation to the value of the services provided;
• Mindlessly trusts and recommends government personnel or political figures instead of relying on the expertise of someone working for recurv. Also, anyone who invests a disproportionate amount of time with government officials or political figures concerning the average client profile constitutes a red flag.

The ABC is subject to change as long as the change(s) made are not considered a relaxation on our efforts to combat corruption and bribery. Therefore, all amendments showing a relaxation should be considered null and void and fall back to their original version. Furthermore, every employee of recurv will be informed of any changes made. In case of a status quo, a refresh will be offered yearly.

Should you wish to file a complaint, or if you have any questions then our compliance officer will gladly help you via email at contact@recurv.be.

At recurv, we are committed to creating a diverse and inclusive workplace where everyone feels valued and respected. We believe that diversity in our workforce brings new ideas, perspectives, and experiences that make us a stronger and more innovative company.

Scope

This policy applies to all employees of recurv, as well as consultants and students working on behalf of the company.

Policy Statement

recurv is an equal opportunity employer committed to providing a workplace free from discrimination, harassment, and bias. We value diversity and inclusion in all aspects of our business, including our recruitment and hiring processes, training and development programs, and day-to-day operations.

Our commitment to diversity and inclusion includes, but is not limited to:

• Race, ethnicity, and national origin;
• Gender and gender identity;
• Sexual orientation and expression;
• Age;
• Religion and belief;
• Disability and health status;
• Social background and class.

We believe everyone has the right to be treated with respect and dignity, and we will not tolerate discrimination, harassment, or bias in our workplace. We encourage all employees to speak up if they witness or experience behaviour inconsistent with our values and principles. 

Recruitment and Hiring

We are committed to recruiting and hiring a diverse workforce that reflects our communities. We will not discriminate based on race, ethnicity, gender, sexual orientation, age, religion, disability, or other characteristics protected by law.

Workplace Environment

We are committed to providing a workplace environment free from discrimination, harassment, and bias. We will not tolerate any behaviour inconsistent with our values and principles. We encourage all employees to treat each other with respect and dignity and speak up if they witness or experience behaviour inconsistent with our values and principles.

Consequences for Violations

We take violations of our diversity and inclusion policy very seriously. Any employee who violates this policy, based on the employment regulation, will be subject to disciplinary action. We encourage all employees to report any violations of this policy to their supervisor or HR.

Conclusion

At recurv, we believe diversity and inclusion are essential to our success as a company. We are committed to creating a workplace free from discrimination, harassment, and bias, where everyone feels valued and respected. We will continue to evaluate our policies and practices and adjust as needed to ensure we meet our values and principles.

recurv acknowledges that negative environmental changes are partly attributable to careless human behaviour. recurv has a healthy reflex on following science while maintaining a prudent, sensible and rational behaviour towards ever-growing, non-legally imposed measures. It follows policy standards applicable to all businesses and applies them a rato the HR sector. The company urges its employees, consultants, clients and suppliers to follow the United Nations’ Sustainable Development Goals, specifically SDG 12: Responsible Consumption and Production. The company aims to minimise waste production while efficiently consuming energy and promoting environmental awareness to all our business partners.

As a key player in the recruitment and consultancy industry, recurv plays its part in raising and promoting sustainability goals by taking the following actions:

• Digitising all aspects of work to minimise paper consumption;
• Working almost exclusively with suppliers who have an environmental policy;
• Placing orders for physical goods once a month to the extent possible to limit the CO² emissions of our suppliers;
• Recycling all outdated electronic devices;
• Turning off all lights, including small LED lights, and programming electrical devices to limit energy consumption;
• Complying with relevant and industry-friendly European, federal and local environmental policies and practices and strictly adhering to regulations and legislation and industry-specific legislation.

In conclusion, at recurv, we are committed to operating in an environmentally responsible manner to minimise our environmental impact while promoting sustainable practices to our stakeholders. We are dedicated to continuously improving our sustainability practices by adhering to relevant industry-friendly policies, regulations, and legislation. Working together can contribute to a healthier planet for present and future generations.

Purpose and Scope

This policy outlines measures taken by recurv BV (hereafter recurv) to protect sensitive information, including personal data, trade secrets, and other confidential information.

This policy applies to all employees, contractors, and freelancers who work with us and any third parties with access to our information, such as clients, suppliers, and partners.

Data Protection

recurv complies with data protection laws and regulations, including GDPR, and ensures lawful, fair, and transparent processing of personal data.

We collect only necessary personal data for our business purposes and use it solely for those purposes. We take all measures required to ensure personal data’s accuracy, completeness, and security.

Confidential Information

recurv protects confidential information and takes necessary measures to keep it confidential and prevent disclosure to unauthorized persons.

We require all employees, contractors, and freelancers to sign a confidentiality clause outlining their obligation to keep confidential information confidential and the consequences of breaching it.

Information Security

recurv takes all necessary measures to ensure the security of our information, including personal data and confidential information. Additionally, we use various technical and organizational measures to protect our information from unauthorized access, loss, or destruction.

We require all employees, contractors, and freelancers to apply industry standard information security measures.

Third-Party Access

We may grant access to our information to third parties, such as clients, suppliers, and partners, and require all third parties accessing our information to sign a confidentiality agreement. In addition, we take all necessary measures to protect our data while it is in their possession.

Compliance and Monitoring

Our company is committed to complying with all applicable laws, regulations, and industry standards related to confidentiality and data protection. Additionally, we regularly review and update our policies and procedures to ensure compliance and monitor our employees, contractors, and freelancers to ensure compliance with our policies and procedures. Finally, we take all necessary measures to investigate and address confidentiality or data protection breaches.

Contact Information

If you have any questions or concerns related to our confidentiality and data protection policies and procedures, please don’t hesitate to contact us at contact@recurv.be.

recurv thrives on providing the highest level of service to our customers, consultants and job seekers. This means that all actions that are taken, all things that are said and deals that are made have been discussed thoroughly with the relevant parties and the representatives of recurv—naturally, the same goes for the back office. Essentially, no important decisions are taken at recurv without applying the four-eyes principle as this ensures, at a minimum, a clean, efficient, ethically and legally well thought out off answer and solution to all questions and problems, may it be, for example, a staffing issue or a simple accountancy discrepancy.

On top of any form of due diligence, recurv communicates transparently with all parties within and outside the company. This creates high trust and allows parties to conduct business responsibly. A key element in our corporate culture of openness is emphasising the importance of written agreements. This way, we minimise, at least on our part, the chances of vagueness and disagreements.

As the management performs strict due diligence and monitors transparency and the strict application of the Codes of Conduct, Deontology and Quality Charter, it cannot completely rule out any misconduct. Human Resources as a branch and business is centered around people, which entails that the odds of any wrongdoing, be it committed with fraudulent intent or simply out of carelessness or imprudence, might exist. Therefore, recurv has created the proper reporting channel to be used by the disadvantaged worker or any other stakeholder who has gained knowledge of any misconduct being committed.

Who is allowed to report on misconduct?

Any stakeholder who has relations or used to have a link with (limited to 2 (two) years after the last communication with the company) recurv, be it an employee, consultant, freelancer, job-seeker, student, retiree, client, managed service provider and or supplier.

What are examples of misconduct?

Any breach committed by any stakeholder as mentioned above with the recurv’s Codes of Conduct, Deontology and Quality Charter, the employment contract and all its annexes.

In addition, any breach committed against standardised good behaviour and customs considered ethically questionable as well as the law, no matter how small or benign its impact is and against recurv’s business procedural working are also considered misconduct behaviour.

The following fall out of the scope of this report: questions regarding your employment conditions, benefits, promotions or demotions, performance review, payroll, timesheet, statement of work, and or personal grievance, conflict or complaint with one of the stakeholders for which the issue is not considered misconduct. These issues must be discussed with your HR manager, the legal department or one of the managing directors.

Should there be any doubt, you might consult with one of the managing directors or the HR manager. If your issue does not fall within the scope of this report, they will refer you to the correct department.

The following factors may determine the level of targeted action:

• Who is (actively or passively) involved in the misconduct?
• Who did what, and are there witnesses (willing to testify)?
• When did it happen?
• Where did it happen?
• How did it happen?
• What was the motivation for the misconduct to take place?
• What evidence is there to support your claim?

Note that clearing out issues respectfully through face-to-face communication with the wrongdoer is the preferred strategy. However, suppose you, as the aggrieved party, are of judgement that it will not solve the problem or even make it worse. In that case, the management team supports your wish to confide with certain persons to help clear the issue. If you wish to keep yourself anonymous towards the wrongdoer, then anonymity is guaranteed. It is, however, essential to realise that anonymity could lengthen and complicate the problem-solving strategy and even, in some instances, make the problem almost impossible to resolve. Furthermore, the person responsible for solutions will look for ways best to his judgement to solve the issue by addressing the wrongdoer.

recurv has appointed a confidant responsible for mediating between the conflicting parties. This person is always available to help you in any situation and may when requested by yourself and judged positively, solve the problem without the support of a direct manager, the legal department or the managing directors. However, should the problem be too complex or involve legal wrongdoing, the appointed confidant will urge the aggrieved party to involve other parties, such as but not limited to the direct manager and/or the managing directors.

The aggrieved party, who acts as a whistleblower, deserves protection from retaliation. Therefore, the integrity of the aggrieved will be monitored, and several evaluations will be done on the progress of the proposed solution. Suppose retaliatory measures have been taken by those guilty of misconduct. In that case, punitive measures will be taken without hesitation, reserving the right to immediate termination of employment. When deemed necessary, a law enforcement agency will be involved.

By all means, the grievance will be examined without delay. A proposed solution will, depending on the accepted resolutionary measure, cooperation of the aggrieved, information given on the wrongdoing and the severity of the issue, be communicated within the first five days after it has been reported.

No later than ten working days will a first approach be taken by the aiding party/parties. Then, when judged successfully, a weekly evaluation for the first month will be done with the aggrieved party and, when seen fit, with the wrongdoer.

Hereunder follows a short visualisation of the reporting channels

Misconduct by employees:

Misconduct from a same-level colleague

Aggrieved party -> direct manager and or appointed confidant -> wrongdoer

Misconduct from direct manager

Aggrieved party -> one of the managing partners and or appointed confidant -> wrongdoer

Misconduct from managing partner

Aggrieved party -> direct manager and or appointed confidant -> wrongdoer

Misconduct from client or candidate

Aggrieved party -> direct manager -> managing partners -> wrongdoer

Misconduct from supplier

Aggrieved party -> appointed confidant -> wrongdoer

Misconduct by middle management:

Misconduct from a same-level colleague

Aggrieved party -> managing partner and or appointed confidant -> wrongdoer

Misconduct from managing partner

Aggrieved party -> appointed confidant -> wrongdoer

Misconduct from client or candidate

Aggrieved party -> managing partner -> wrongdoer

Misconduct from supplier

Aggrieved party -> appointed confidant -> wrongdoer

The following parties are considered as Point of Contact (PoC) for aggrieved parties:

• The appointed confidant is Matthias Van den Bempt. His contact detail is matthias@recurv.be. Depending on the wrongdoing and the severity, he will act in the capacity of the Managing Partner. He will let Simon Peeters be involved in the decision-making and mediation whenever necessary. In absence of Matthias Van den Bempt, Simon Peeters will be the appointed confidant.
• Marwan Morowa runs the legal department. His contact detail is marwan@recurv.be. He will act as a PoC for issues with suppliers and everything related to the infringement of the law.
• The direct manager is Aristide Giramahoro. He serves as the middleman for both managing directors. His contact detail is aristide@recurv.be.