1. Purpose of the Procedure

This procedure aims to define the internal methods for implementing the Law of May 16, 2023, which transposes Directive (EU) 2019/1937 on the protection of persons reporting breaches of European Union law ("the Law").

This procedure does not apply to “Customer Complaints,” which are subject to a specific procedure.

2. Scope

This procedure applies to all employees of Voyages Emile Weber, as well as external partners (suppliers, service providers, and others) wishing to report irregularities.

3. Definitions

• Whistleblower: Any person (employee, external partner) who, in good faith, reports an irregularity, fraud, or unethical behavior.
• Report: Communication of information concerning a situation or facts that are contrary to European or national law, human rights, or professional conduct and ethics rules.

4. Reporting Methods

Reports can be submitted via the following channels:

• In writing: Send a detailed letter to: 
  Voyages Emile Weber
  Attention: Compliance Officer
  Z.A. Reckschleed
  L-5411 Canach
• By e-mail: use the dedicated and secure email address: whistleblowing@ew.lu
• Online-Form: complete the notification form below, which is available on the company's intranet or website.
• Via external reporting channels provided by the Law.

Please use the PDF form provided to send us a notification by letter or e-mail.

5. Contents of the Report

The report should include the following information:

• Identity of the whistleblower (anonymity possible).
• Detailed description of the observed facts.
• Dates and locations of the reported events.
• Any supporting documents or available evidence.

6. Handling Reports

• Acknowledgment of receipt: An acknowledgment of receipt will be sent to the whistleblower within 7 days of receiving the report (unless anonymity is requested).
• Preliminary review: An initial analysis will be performed in order to determine the nature and seriousness of the reported facts.
• Investigation: A thorough investigation will be conducted by the Compliance Officer or a designated committee, respecting confidentiality and the rights of the involved parties.
• Report and corrective actions: A report will be prepared following the investigation, and corrective measures will be implemented if necessary.

7. Protection of the whistleblower

Voyages Emile Weber is committed to protecting whistleblowers from any form of retaliation or discrimination. Anonymity can be ensured if requested, and all information will be treated with the strictest confidentiality.

8. Monitoring and Revision

This procedure will be regularly reviewed and updated as needed to ensure its effectiveness and compliance with legislative and regulatory developments.