Whistleblowing Policy

Greece Lean Six Sigma (GLSS)

Effective Date: 02.05.2024
Last Review: 02.05.2025
Policy Owner: Victoria Tsolidou, Founder & Managing Director
Version: 1.0
Status: Public Governance Policy

1. Purpose

Greece Lean Six Sigma (GLSS) is committed to maintaining the highest standards of integrity, transparency, accountability, and ethical conduct across all its activities.

This Whistleblowing Policy establishes a safe, confidential, and trusted framework for reporting concerns related to unlawful, unethical, or improper conduct, without fear of retaliation.

The policy aims to:

  • Encourage early reporting of misconduct
  • Protect whistleblowers acting in good faith
  • Ensure fair, independent, and confidential investigation
  • Strengthen governance, compliance, and ESG integrity

2. Scope of Application

This policy applies to:

  • The Founder & Managing Director
  • Employees and external collaborators
  • Trainers, assessors, examiners, invigilators
  • Authorized partners, agents, and contractors
  • Suppliers and service providers
  • Any individual interacting with GLSS who becomes aware of misconduct

It covers all GLSS activities, including training, certification, consulting, governance, financial operations, and partnerships.

3. What Can Be Reported

A whistleblowing report may concern, but is not limited to:

3.1 Legal & Regulatory Violations

  • Breach of laws or regulations
  • Non-compliance with ISO standards or accreditation rules
  • GDPR or data protection violations

3.2 Ethical & Professional Misconduct

  • Corruption, bribery, fraud, or financial misconduct
  • Conflict of interest not declared
  • Abuse of authority or position

3.3 Certification & Assessment Integrity

  • Bias, favoritism, or manipulation in training, assessment, or certification
  • Undue influence on exam or certification outcomes
  • Breach of impartiality (ISO/IEC 17024)

3.4 Workplace & Social Responsibility Issues

  • Discrimination, harassment, or bullying
  • Violations of gender equality, neurodiversity, or inclusion policies
  • Retaliation against whistleblowers

3.5 Environmental, ESG & Governance Issues

  • Misrepresentation of ESG performance
  • Environmental negligence or unethical practices
  • Misuse of GLSS brand, data, or intellectual property

4. Who Can Raise a Concern

Reports may be submitted by:

  • Employees and collaborators
  • Trainers and assessors
  • Learners and certification candidates
  • Partners, suppliers, or third parties

Reports may be:

  • Named, or
  • Anonymous (encouraged where safety is a concern)

5. Reporting Channels

Concerns may be reported through the following secure channels:

📧 Email: whistleblowing@greeceleansixsigma.gr
📧 Alternative (confidential): info@greeceleansixsigma.gr (marked “Whistleblowing – Confidential”)

Reports should include, where possible:

  • Description of the concern
  • Date(s) and context
  • Persons involved
  • Supporting evidence (if available)

Lack of evidence will not prevent investigation if the report is made in good faith.

6. Protection of Whistleblowers

GLSS strictly prohibits any form of retaliation, including:

  • Dismissal or termination of collaboration
  • Demotion, discrimination, or exclusion
  • Harassment, intimidation, or reputational harm

Any retaliatory action will be treated as a serious disciplinary breach.

Whistleblowers acting in good faith are protected even if the investigation does not substantiate the concern.

7. Confidentiality & Anonymity

  • All reports are treated as strictly confidential
  • Information is disclosed only on a “need-to-know” basis
  • Anonymous reports are accepted and investigated to the extent possible
  • Personal data is handled in accordance with GDPR and ISO/IEC 27701

8. Investigation Process

  1. Acknowledgement of receipt (where contact details are provided)
  2. Preliminary assessment of scope and risk
  3. Independent investigation, proportional to the allegation
  4. Documentation and evidence review
  5. Corrective and preventive actions, if required
  6. Closure and record retention

Investigations are conducted objectively, fairly, and without conflict of interest.

9. False or Malicious Reports

Knowingly false, misleading, or malicious reports may result in disciplinary action.
This does not apply to reports made in good faith that later prove unsubstantiated.

10. Governance & Responsibility

  • Overall responsibility: Founder & Managing Director
  • Oversight integrated into:
    • Management Review
    • ESG Governance
    • Certification & Ethics Committees
  • Records maintained securely and confidentially

11. Alignment with Standards & Legislation

This policy aligns with:

  • EU Whistleblower Protection Directive (EU 2019/1937)
  • ISO 9001 – Quality Management
  • ISO 21001 – Educational Organizations
  • ISO/IEC 17024 – Certification of Persons
  • ISO 26000 – Social Responsibility
  • ESG & ethical governance principles
  • GLSS Code of Ethics & Conduct

12. Review

This policy is reviewed annually or earlier if required due to:

  • Legal changes
  • Accreditation requirements
  • Material incidents or audit findings

Issued by:
Victoria Tsolidou
Founder & Managing Director
Greece Lean Six Sigma