Whistleblowing Policy

Otofacto, part of The Positive Thinking Company, is committed to being a responsible company and promotes ethical business conduct for all its stakeholders.

To support its commitment, The Positive Thinking Company is implementing its first Whistleblowing Policy in accordance with the requirements of the European Whistleblowing Directive. The tool will be implemented in Belgium, France, Luxembourg, Germany, Bulgaria, Austria and Switzerland.

A Whistleblower is a person who exposes information or an activity within our company that is deemed illegal, illicit, unsafe, a waste, fraud, or abuse of taxpayer funds. This Whistleblowing procedure allows witnesses or victims of serious incidents within the company to report facts or suspicions, while protecting them from any negative repercussions. Negative repercussions can be dismissal, demotion, reduction in wages, negative performance assessments, etc. …

This Whistleblowing procedure will apply to the following persons: all employees, interns, volunteers, suppliers, subcontractors, clients, facilitators/intermediaries, shareholders, ex-employees, future employees during the recruitment process and third parties who are related to someone who works for the company and who could suffer retaliation in a work-related context.

The incidents and/or breaches which can be reported are the following:

  • Bribery and corruption;
  • Breaches of competition law;
  • Conflicts of interest;
  • Fraud;
  • Financial crimes;
  • Moral or sexual harrassment (excluded for France and Switzerland who have their own internal procedure);
  • Discrimination;
  • Physical violence in the workplace

You can make your reporting through the following link: https://positivethinking.integrityline.com. Please don’t forget to choose your country and language before making the reporting.

Please be sure to read the Whistleblowing Policy in advance, which you can also find on the link mentioned above.

Should there be any concerns about this procedure, please address your questions to the Business Ethics Committee through the following e-mail address: BE_legal@positivethinking.tech.