Whistleblowing Policy

The ORFIUM Group of Companies (“Group”) prioritises the conduct of its business in a responsible and lawful manner.    

In this context, our Group encourages a corporate speak up culture in its workplace and ensures that its employees and other reporting persons feel safe sharing their concerns and report misconduct about potential violations of European Union legislation.

To this end, we have established and put into operation an internal reporting channel (“Channel”) through the present safe online platform for the submission of reports regarding the violation of EU law in the following areas:

  1. public procurement; 
  2. financial services, products and markets, and prevention of money laundering and terrorist financing; 
  3. product safety and compliance; 
  4. transport safety; 
  5. protection of the environment; 
  6. radiation protection and nuclear safety; 
  7. food and feed safety, animal health and welfare; (viii) public health; (ix) consumer protection; 
  8. protection of privacy and personal data, and security of network and information systems; 
  9. competition and state aid rules; and 
  10. other sectors of law falling within the material scope of the Whistleblowing Directive, as transposed in national legislation.

Internal reports may be submitted by Orfium employees, agents, trainees, volunteers, contractors, subcontractors, suppliers, persons working for Orfium through third-party suppliers and persons belonging to the administrative, management or supervisory body of Orfium or the Group and to any persons who acquire information through their work-related activities with the Group.

Internal reports may be submitted by electronic means through our online platform available in this webpage. Alternatively, internal reports may be submitted orally through a personal meeting with the Person designated to handle the Receipt and Follow-up of Reports (“Designated Person”) within a reasonable time, at the request of the reporting person, sent at the following e-mail address: tellme@orfium.com.

Our online whistleblowing platform is hosted in our secure servers. Any report you make will be kept strictly confidential and will not be disclosed to any third party other than the Orfium Designated Person and authorised staff members responsible for receiving, or following up on, reports.

You may submit reports both by name and anonymously. In the case of reports by name, we will pseudonymize any personal data being processed.

The operation of the Orfium Whistleblowing Channel as well as the receipt, monitoring, management, follow-up and archiving of reports are further specified in detail by the specific terms of the Group’s Whistleblowing Policy, as in force from time to time, which is available at the following link: (“Policy”).

Before submitting a report you are required to read carefully and understand our Orfium Whistleblowing Notice, which provides in detail information (i) about the operation of the Channel, the procedures for following up on reports and their rights; and (ii) about the processing of personal data during the operation of the Channel and the management of reports.

Orfium Whistleblowing Notice

Whistleblowing Policy Form