The Whistleblowing Policy of the FREE Network explains how to safely report concerns, understand your rights, and access the legal support available under the EU directive.

We at the FREE NETWORK, a joint initiative by SITE (Stockholm), BEROC (Minsk), BICEPS (Riga), CenEA (Szczecin), ISET-PI (Tbilisi), and KSE Institute (Kyiv), are committed to the highest standards of transparency, honesty, and accountability. To ease and facilitate the process for our employees, as well as relevant third parties who interact with the FREE NETWORK, this Whistleblowing Policy provides clear guidance on how to safely raise serious concerns regarding aspects of work carried out under this initiative. It informs you, as a whistleblower, about the support available to help you express concerns securely, who to contact, and how to file a whistleblowing report.

The policy also explains how we ensure that the support provided is responsible and compliant with the law, including Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law (the “Whistleblowing Directive”). In addition, it outlines your rights and how you can exercise them. If you have any questions about this Whistleblowing Policy or the process for filing a report, please contact us using the details provided below.

1. Who Can Be a Whistleblower?

1.1. As a whistleblower, you may be an employee of the FREE Network, a person with self-employed status, a shareholder, or a member of the administrative, management, or supervisory body of an undertaking. You may also be a volunteer, or a paid or unpaid trainee. Additionally, you may be a person working under the supervision and direction of contractors, subcontractors, or suppliers to the FREE Network.

1.2. Please note that you may still qualify as a whistleblower even if your work-related relationship with us has ended, or if it has not yet begun.

2. Who Is Responsible for the Whistleblowing Report?

2.1. The Stockholm Institute of Transition Economics (SITE), as the lead organisation in the FREE Network, is responsible for whistleblowing reports filed under this Policy. SITE is obligated to protect you, including by not disclosing your identity to anyone beyond the authorised persons handling your report (unless you explicitly consent or disclosure is required by law), and by ensuring you are not subject to retaliation.

2.2. Please note that you also have responsibilities under this Policy. We expect you to only report information and personal data relevant to a specific whistleblowing report. Personal work-related grievances, such as interpersonal conflicts or employment-related decisions, should not be reported through this system but instead raised with the SITE Admin Director or Director.

3. What Can Be Reported in a Whistleblowing Report?

3.1. If, through your work-related relationship with us, you acquire information and have reasonable grounds to believe that misconduct or breaches of applicable rules or regulations have occurred, you are encouraged to file a whistleblowing report.

3.2. The Whistleblowing Directive highlights the importance of reporting in the following areas:

• (i) public procurement;
• (ii) financial services, products, and markets, and prevention of money laundering and terrorist financing;
• (iii) product safety and compliance;
• (iv) transport safety;
• (v) environmental protection;
• (vi) radiation protection and nuclear safety;
• (vii) food and feed safety, animal health and welfare;
• (viii) public health;
• (ix) consumer protection;
• (x) protection of privacy and personal data;
• (xi) harassment and unethical conduct.

We strongly encourage you to file a report on any such matter.

3.3. Reasonable grounds to believe means that, in light of the circumstances and the information available to you at the time of filing the report, you believe the matter reported to be true.

4. Where Can You File a Whistleblowing Report?

4.1. You may file a report in writing via SITE’s website or email, or orally to the SITE Admin Director or Director. Oral reporting may be done by telephone [or through other voice messaging systems] and, upon request, in person with a designated impartial contact as listed below.

4.2. Reports may also be submitted through SITE’s external whistleblowing system, Whistlelink, managed by Whistleblowing Solutions AB. This service is available 24/7 at: hhs.whistlelink.com.

4.3. We will acknowledge receipt of your report within seven days. SITE has designated impartial persons/departments to follow up on reports. They will maintain communication with you, request additional information if necessary, and provide feedback no later than three months after acknowledgement.

4.4. Reports may also be filed anonymously. This does not affect your rights under the EU Whistleblowing Directive, although anonymity may make investigation more difficult.

4.5. If internal reporting is inappropriate or not possible, you may file a report externally with competent authorities, and where relevant, with EU institutions, bodies, offices, or agencies. Contact information is available here >>.

5. Personal Data

5.1. We are committed to protecting the personal data we process. This means safeguarding your privacy and complying with applicable data protection laws, including the General Data Protection Regulation (GDPR).

5.2. When you file a report, the personal data included will be processed to fulfil our legal obligations under, among other instruments, the Whistleblowing Directive.

6. What Are Your Rights?

6.1. We are committed to implementing and maintaining adequate measures to prohibit retaliation against you for filing a whistleblowing report. This includes threats of retaliation and attempts at retaliation.

6.2. Examples of prohibited retaliation include:

• (a) suspension, lay-off, dismissal, or equivalent measures;
• (b) demotion or denial of promotion;
• (c) reassignment of duties, change of workplace, reduction in wages, or change in working hours;
• (d) withholding of training opportunities;
• (e) negative performance assessment or employment reference;
• (f) disciplinary action, reprimand, or other penalty, including financial penalties;
• (g) coercion, intimidation, harassment, or ostracism;
• (h) discrimination or unfair treatment;
• (i) failure to convert a temporary contract to permanent employment where there was a legitimate expectation;
• (j) non-renewal or early termination of a temporary contract;
• (k) harm to reputation, including through social media, or financial loss;
• (l) blacklisting that prevents future employment;
• (m) early termination or cancellation of a contract for goods or services;
• (n) cancellation of a licence or permit;
• (o) forced psychiatric or medical referrals.

6.3. In addition to this Policy, competent authorities provide independent, accessible, and free information on available procedures, remedies, protection against retaliation, and your rights. Contact information is available here.

How to Contact Us?