Whistleblowing

 The following people may make a whistleblowing report and are protected under the Whistleblowing Law:

• Persons working in the private sector and who have information about violations obtained in a professional context, including at least:

                 - Persons with the status of employee or self-employed person.
                 - Shareholders and members of the management or the Board of Directors, including non-executive members;
                 - Volunteers and paid or unpaid trainees;
                 - Contractors, subcontractors and suppliers.

• Persons whose employment relationship has since been terminated or has not yet started (applicants) and insofar as the information about violations was obtained during the hiring process or other pre-contractual negotiations.
• Persons who pass on information obtained outside a professional context, insofar as it is a violation in the field of financial services, products and markets or any violations against it in the area of preventing money laundering and terrorist financing.

The following persons are equally protected under the Whistleblowing Law:

• Facilitators (persons who assist the whistleblower in the reporting process and whose assistance should be confidential).
• Third parties associated with the whistleblower and who are at risk of retaliation in a professional context (such as colleagues or relatives of the whistleblower).
• Legal entities owned by or associated in a work-related context with the whistleblowers.
• Whistleblowers who pass on information obtained outside a work-related context, insofar as it is a violation in the field of financial services, products and markets or any violation in the area of preventing money laundering and terrorist financing.

A person can report a serious concern about suspected or actual criminal conduct, unethical conduct or any other misconduct relating to any of the following, although this is not an exhaustive list:

• Public tenders.
• Financial services, products and markets, avoidance of money laundering and terrorism financing.
• Consumer protection.
• Protection of private life, data protection, protection of network and information systems.
• Tax fraud
• Social fraud
• Criminal offences.
• Any failure to comply with a legal obligation.
• Miscarriages of justice.
• Threats to, or harm caused to, people’s health and safety.
• Threats to, or harm caused to, the environment.
• Attempts to conceal any of the above matters.

All whistleblowing reports will be dealt with confidentially. This means that the identity of the whistleblower cannot be disclosed to persons other than the Whistleblowing Officer, without his or her free and explicit consent. This also applies to all other information from which the identity of the whistleblower can be derived directly or indirectly.

Whistleblowers who make whistleblowing reports in a reasonable belief that an issue covered by the applicable legislation has occurred, is occurring or will occur, even if they turn out to be mistaken must not be threatened, retaliated against, harassed or bullied in any way.

Within Lloyd’s Europe the Compliance Department will take up the role of Whistleblowing Office.

As an independent control function, the Compliance Department can be considered as independent and free from any conflicts of interest.

Whistleblowing reports can be made to the following e-mail address: LloydsEurope.Whistleblowing@lloyds.com

The helpline is available to the company’s employees, contractors and consultants and staff employed by other Lloyd’s entities. It can also be used by those who were previously in such roles, for example, former employees and former contractors.

The whistleblowing helpline is operated by an independent, third party organisation called Safecall. It is a completely confidential service and whistleblowing reports can be made anonymously if the whistleblower wishes to do so.

Telephone:

Country Freephone Availability
Australia 1800 312928
Austria 00800 7233 2255
Belgium 00 800 72332255
Brazil 0800 892 1750
Canada 1877 59 98073
China China Unicom/Netcom  10800 7440605
China China Telecom 10800 4400682
China (Shared Cost) 4008 833405
Colombia 01800 9448040
Denmark 00 800 72332255
France 00 800 72332255
Germany 00 800 72332255
Greece 00800 44141966
Hong Kong 3077 5524
India 000 800 4401256
Ireland 1800 812740
Israel 012 800 72332255 (Golden Lines)
Israel 013 800 72332255 (Barak)
Israel 014 800 72332255 (Bezeq)
Italy 00 800 72332255
Japan 0120 921067
Lithuania 00 800 7233 2255
Malta +44 191 516 7751
Mauritius 802 044 0038
Mexico 01800 1231758
Namibia +44 191 516 7764
Netherlands 00 800 72332255
New Zealand 00 800 7233 2255
Norway 00 800 7233 2255
Poland 00 800 72332255
Portugal 00 800 72332255
Singapore 800 4481773
South Africa 0800 990243
Spain (inc. Canary Is.) 00 800 72332255
Sweden 0850 252 122
Switzerland 00 800 72332255
UAE 8000 4413376
UK 0800 9151571
USA 1 866 901 3295
Zimbabwe +44 191 516 7764

www.safecall.co.uk/report

A whistleblowing report may be submitted to the National Bank of Belgium (NBB) or Financial Services and Markets Authority (FSMA) regarding matters within their respective areas of supervision. The NBB supervises prudential matters and the FSMA supervises conduct of business areas.

 

National Bank of Belgium (NBB)

The NBB’s contact details for the department of Insurance Supervision are as follows:

National Bank of Belgium
Boulevard de Berlaimont 14
1000 Brussels
Belgium

Telephone: +32 2 221 27 31
Email: insurance.supervision@nbb.be
Website: www.nbb.be/en/financial-oversight/general/report-breach



Financial Services & Markets Authority (FSMA)

The FSMA’s contact details are as follows:

Investigations Officer, Confidential – LAK2392
Investigations Officer
Enforcement Department
Financial Services and Markets Authority
Rue du Congrès 12
1000 Brussels
Belgium

Telephone: + 32 2 220 56 66
Website:

www.fsma.be/en/faq/whistleblowers-point-contact (English)

www.fsma.be/fr/faq/point-de-contact-lanceurs-dalerte (French)

www.fsma.be/nl/faq/contactpunt-klokkenluiders (Dutch)

The website above contains information about how a whistleblowing report can be submitted, how it will be handled by the FSMA and the protection that the FSMA will give to the whistleblower. Whistleblowing reports can be made to the FSMA anonymously if the whistleblower wishes to do so.

Whistleblowing reports can be submitted to the FSMA online in French or Dutch via the links below.

https://whistleblowing.fsma.be/fr/ (French)
https://whistleblowing.fsma.be/nl (Dutch)

An appointment for a face to face meeting with the FSMA to report or discuss a whistleblowing matter can be made via the links on its website above or by telephoning the number above. Telephone calls to this number are not recorded.



Federal Ombudsman

The Federal Ombudsman has the role of Federal Coordinator of external whistleblowing reporting in the private sector.

In this role, the Federal Ombudsman can be contacted with whistleblowing reports related to the financial services sector by the protected persons under the Belgian Whistleblowing Law.

The Federal Ombudsman’s contact details for the filling of whistleblowing reports are as follows:

• Online whistleblower reporting form:
  
  https://www.federaalombudsman.be/en/whistleblower-reporting-form

• E-mail:
  
  Send an e-mail to: integrity@federalombudsman.be

• By appointment:
  
  Send an e-mail to: integrity@federalombudsman.be  or call 0800 999 61 or +32 (0)2 289 27 27 to make an appointment with a member of the Integrity Centre.

1.1 Scope

To be read in conjunction with Section 1.2.2 in above policy.

Article 2 of the Spanish Law 2/2023 includes in the scope of the law:
1) any action or omission that may constitute an infringement of the EU Law as set out in the Whistleblowing Directive, or affect the financial interests of the EU or relate to the internal market and
2) any action or omission that may constitute a serious or very serious infringement of the administrative law.

1.2 Data Protection

To be read in conjunction with Section 3.1.3 in above policy.

The Spanish Law 2/2023 establishes specific deadlines to be met concerning the retention and deletion of personal data. These deadlines are in line with those set out in current data protection regulations. In particular, reports may only be kept in the information system for the time necessary to decide whether or not to initiate an investigation. If a decision is not made within three months, the report must be deleted from the system.

1.3 Internal channels

To be read in conjunction with Section 3.2.1 in above policy.

If requested by the whistle-blower, LIC will arrange an in person meeting regarding the filing of a whistleblowing report and this within maximum 7 days.

1.4 External channels

To be read in conjunction with Section 3.2.2 in above policy.

The Spanish Law 2/2023 creates an additional external whistleblowing channel, which is supervised by the Autoridad Independiente de Protección del Informante, A.A.I, or by the relevant regional authority.  

Any individual may inform the Autoridad Independiente de Protección del Informante of an infringement set out in the Spanish Law 2/2023, whether in the public or private sector, directly or after making a report through an internal channel. 

If accepted for processing, the Autoridad Independiente de Protección del Informante will then investigate to check the veracity of the report and ultimately issue a decision. These proceedings cannot take longer than three months. Decisions issued by this Authority will not be appealable.  

The Autoridad Independiente de Protección del Informante, A.A.I was created on 30 October 2024, although it is not operational yet.

1.5 Communication

To be read in conjunction with Section 5 in above policy.

In line with the Spanish Law of 2/2023, LIC will publish the whistleblowing policy on the home page of LIC, in a separate and easily identifiable section. 

1.6 Whistleblowing register

To be read in conjunction with Section 3.3.2 in above policy.

All whistleblowing reports will be recorded in a confidential and secure whistleblowing register. The information registered in the whistleblowing register will be retained for a maximum period of 10 years.

1.7 Timescales

To be read in conjunction with Section 3 in above policy.

LIC will ensure that the investigations are undertaken as quickly as possible without affecting the quality and depth of those investigations.

The whistle-blower will receive a confirmation of receipt that his whistleblowing report has been received within seven calendar days.