The Social Hub is committed to embedding a culture of effective communication, openness and a willingness to co-operate and listen. There may be occasions when misunderstandings, problems or concerns are raised and need to be resolved. Most of these issues can be dealt with in an informal manner. There may be times, however, when such issues are unresolved and may become grievances. These relate to unwanted behaviour, bullying, (sexual) harassment or discrimination.   

If you are experiencing this in any way, we want you to come to us, using our Grievance Policy below. Undesirable behaviour is never tolerated, and we are here in support of any victims of this. What is discussed is, without exception, strictly confidential and will only be shared with others with your deliberate consent. All information is owned by you, as the person making the report. Nothing is shared without permission.   

1. Written grievance

The grievance may be submitted to the trust counsellors appointed by The Social Hub via email: trust.consultant@thesocialhub.co

The grievance should include the following: 

• the nature of the complaint
• the names of the accused and any other individual(s) involved
• the date(s) and time(s) of the incident(s)
• any supporting documents the complainant may have
  
  

2. Grievance hearing

Within two weeks after receiving the grievance, The Social Hub’s trust counsellor will invite the complainant and the accused to separate hearings. The complainant and the accused are allowed to be accompanied to the hearing, for example by a legal advisor, a family member or a friend.   

The complainant and the accused will receive a written notification of the hearing details, which include the following: 

• date and time
• attendees at the hearing, including The Social Hub’s trust counsellor who will attend to provide procedural advice and take notes
• right of representation at the hearing

There will be minimum of three days between the invitation to the grievance hearing and the hearing.

A representative from The Social Hub will draw up a written report at each hearing. A copy of the report will be sent to the complainant and the accused within one week after the grievance hearing for their approval and signature. This should be returned within one week after receipt.   

What is discussed is, without exception, strictly confidential and will only be shared with others by the confidential advisor with the approval of the person making the report. The reporter retains control and determines how and with whom the information may be shared.     

3. Response to hearing report

The complainant and the accused will be given the opportunity to respond to each other’s points of view in writing. They will receive copies of each other’s hearing reports thereto within one week after their approval of the reports. The written response should be sent to The Social Hub’s representative assigned to the grievance case, within one week after receipt of the hearing reports.   

4. Further investigation

It may be necessary to gather further information before a decision can be made. The complainant and the accused will be kept informed of the timescale and the progress of the investigation. The complainant and the accused will receive a written notification if the investigation is closed.   

5. Decision

Within one month after conclusion of the investigation, a decision about the grievance will be taken by The Social Hub’s representative. The complainant and the accused will receive a written copy of the decision.    

The decision will include the following:

• whether the grievance is (partially) founded or unfounded
• the decision on any disciplinary measures, which may include, but are not limited to, a written warning, contract termination, suspension or dismissal
  
  

6. Appeal

If the complainant and/or the accused do not agree with the decision, it is possible to appeal to The Social Hub’s General Counsel by writing to The Social Hub’s representative responsible for the case. The appeal should be sent within two weeks of the date on which the decision was sent.   

The other party (complainant or accused) will be provided with the appeal and may contest to it in writing. The defence must be sent to The Social Hub’s representative responsible for the case within one week after receipt of the appeal. Within two weeks after receipt, The Social Hub’s General Counsel will decide on the appeal and respond in writing. If the decision on the appeal is not satisfactory for the complainant and/or the accused, they can turn to the court.

This procedure is specifically aimed at dealing with the suspicion of a serious wrongdoing, as specified below. If you have other concerns, please refer to our Grievance Procedure Policy.

The Social Hub is committed to operating in a transparent, fair and ethically responsible way. If you suspect serious wrongdoing, our Whistleblowing Policy describes when and how you can report it and how your information is handled.

It is important to stress that if the report is made in good faith, a reporter is protected as a guest, supplier or employee against unfair treatment, such as, but not limited to, contract termination, demotion, disciplinary measures and dismissal. Therefore, please do not hesitate to make use of this policy.

Who

This policy applies to any person who learns, stays, works and plays at The Social Hub, and/or any person who carries out or has carried out work under a supplier contract governed by civil law or a public appointment with The Social Hub.

What?

Whistleblowing is the act of disclosing information to The Social Hub or to the relevant authority by an individual who knows, or suspects, that the company or an employee is responsible for or is taking part in serious wrongdoing.

When?

You should report your concern when you suspect that a serious wrongdoing exists within The Social Hub and that the concern is based on reasonable grounds, arising from knowledge that you acquired during your stay at, work for or with The Social Hub.

How?

If you have a concern about a serious wrongdoing, report your concern by taking the steps outlined below.

Report the concern about a serious wrongdoing here >

If a reporter wishes, they may consult an advisor in confidence, at their own expense, regarding the concern of the serious wrongdoing.

Anonymity and confidentiality

Reporters have the option to remain anonymous when completing the whistleblowing intake form. The Social Hub does, however, advise individuals to identify themselves when they make a report. This ensures that The Social Hub can appropriately review the report and discuss it with the reporter. The report will be treated confidentially, unless local law requires otherwise. In order for The Social Hub to review the report, and as permitted by applicable law, the reporter can be requested to keep the information contained in the report confidential.

All information regarding the report is stored in such a way that it is only accessible to the persons involved in dealing with this report.

Investigation process

1. The report can be verbal or in writing. Verbal reports will be recorded in writing and provided to the reporter.

2. The Social Hub’s Whistleblowing Team will start an investigation into the report, unless the concern is (i) not based on reasonable grounds or (ii) it is clear that the report does not relate to a serious wrongdoing. Whether an investigation is started will be decided within two weeks after receipt of the report, of which the reporter will receive written confirmation. The written confirmation will include the starting date of the investigation.

3. If it is decided that an investigation will not be started, the reporter will be informed in writing within two weeks after receipt of the report. This response will include the reasons why The Social Hub believes no investigation is required based on this policy.

4. If it is decided that an investigation will be started, The Social Hub’s Whistleblowing Team will assign the investigation to investigators who are independent and impartial. The investigation will not be carried out by persons who may be or may have been involved in the serious wrongdoing.

5. The reporter will be invited to a meeting with the investigators as soon as reasonably possible after the start of the investigation, but within 10 working days at the latest. During this meeting, the reporter will be given the opportunity to elaborate on the report. The reporter is allowed to be accompanied to the hearing, for example by a legal advisor, family member, friend or colleague. A copy of the report of this meeting will be provided to the reporter for approval and signature.

6. The investigators may interview other individuals if deemed necessary. This will be recorded in writing and the record of the meeting will be provided to the individual involved for approval and signature.

7. The Social Hub’s Whistleblowing Team shall decide whether an external body (as defined under ‘external reporting’ below) needs to be notified about the report. If The Social Hub informs an external body, the Whistleblowing Team shall send the reporter a copy of this communication, unless The Social Hub has a serious objection to this.

8. The investigators will inform the person(s) to whom a report relates about the report and, if applicable, about the fact that an external body has been notified, unless this could have a detrimental effect on the investigation or on enforcement. If the investigators deem this necessary for the investigation, such person(s) will be invited to a meeting as part of the investigation. In case such meeting will take place, a copy of the report of this meeting will be provided to the person(s) for approval and signature.

9. The investigators may consult and request all documents within The Social Hub that they reasonably consider to be necessary to carry out the investigation.

10. The investigators will notify the reporter and the person(s) to whom a report relates when the investigation is closed.

Outcome

After conclusion of the investigation, The Social Hub’s Whistleblowing Team will provide the reporter with the investigation report within eight weeks, unless The Social Hub has a serious objection to this.

At the same time, The Social Hub’s Whistleblowing Team will inform the reporter about The Social Hub’s official position regarding the investigation report. This will also include the formal action taken by The Social Hub, if any, as a result of the investigation report, unless The Social Hub has a serious objection to this.

If it is not possible to issue the investigation report within the aforementioned period, The Social Hub will inform the reporter when the investigation report is expected and explain why this longer period is necessary.

The Social Hub’s Whistleblowing Team shall decide whether an external body needs to be notified about the investigation report. The Social Hub’s Whistleblowing Team shall send the reporter a copy of this communication, unless The Social Hub has a serious objection to this.

The reporter will be given the opportunity to comment in writing on the investigation report and the position of The Social Hub. The reporter should send this response within two weeks after receipt of the investigation report.

If, in response to the investigation report or the position adopted by The Social Hub, the reporter states, giving reasons, that the report has not been (properly) investigated or that there are fundamental inaccuracies in the investigation report or the position adopted by The Social Hub, The Social Hub shall respond to these specific points in writing within two weeks after receipt of the response.

External reporting

A reporter may report the concern about a serious wrongdoing externally to the external body as defined below in the following instances:

• the reporter disagrees with the position of The Social Hub based on the investigation report and believe that the issued concerns have been unfairly rejected.
• the reporter has not been notified about the position adopted by The Social Hub within the eight weeks period mentioned above.

Before the reporter reports to the external body, the reporter will inform The Social Hub’s Whistleblowing Team. The Social Hub’s Whistleblowing Team may report the concern about a serious wrongdoing as set forth in the investigation process.

An external body, for the purpose of this policy, refers to the most appropriate body to report a concern about a serious wrongdoing externally. Such body includes:

• a body responsible for investigating criminal offences.
• a body responsible for monitoring compliance with any requirements imposed by local law or under statutory authority.
• any other competent body to which concerns about a serious wrongdoing can be reported. In the Netherlands, the investigation department is the House for Whistleblowers >

If the report is made in good faith, a reporter is protected against unfair treatment, such as, but not limited to, demotion, disciplinary measures, dismissal and contract termination.

The Social Hub does not, however, extend this protection to someone who reports a concern they know to be untrue, or if the report is made to the media and/or by unacceptable use of social media. Such conduct may lead to losing the protection under this policy and/or disciplinary action up to and including dismissal and/or contract termination.

The Social Hub will ensure that the reporter’s managers and colleagues refrain from any form of unfair treatment in connection with the report in good faith.

Protection of others involved

The Social Hub will ensure that others involved with the report, including, but not limited to, the investigators, advisors and other individuals involved in the investigation making a statement in good faith, will be protected against any unfair treatment.

The Social Hub may take disciplinary actions that are fair, reasonable and proportionate against the person(s) to whom the report relates in case the report is deemed to be well-founded.