Whistleblowing Policy

Whistleblowing at LIH

At the Luxembourg Institute of Health (LIH), we are committed to maintaining the highest standards of integrity, transparency, and accountability in everything we do.

In accordance with the Law of 16 May 2023, which transposes Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law, LIH provides a secure framework for reporting concerns about misconduct, illegal activities, or unethical behaviour.

Anyone who reports concerns in good faith can do so safely, confidentially, and without fear of retaliation.

Who can report?

The Law of 16 May 2023 protects individuals who obtain information about breaches in a work-related or professional context, including:

  • LIH employees;
  • Self-employed persons working with LIH;
  • Shareholders and members of administrative, management, or supervisory bodies, including non-executive members;
  • Volunteers;
  • Paid and unpaid trainees;
  • Individuals working under the supervision or direction of LIH contractors, subcontractors, or suppliers.

Protection before, during, and after employment

Protection applies not only to current employees but also to individuals who:

  • Obtained information during a previous employment relationship with LIH;
  • Learned about potential breaches during the recruitment process or pre-contractual negotiations, even if the employment relationship never began.

Additional protected persons

The law also protects:

  • Facilitators: individuals who assist a reporting person in a confidential manner;
  • Third parties connected to the reporting person who may face retaliation in a professional context, such as colleagues or relatives;
  • Legal entities owned by, employing, or otherwise professionally connected to the reporting person;
  • Individuals who report breaches directly to relevant bodies, offices, or agencies of the European Union.

What is not covered?

The legal protection does not apply to reports concerning:

  • National security matters;
  • Information protected by:
    • Medical professional secrecy;
    • Legal professional privilege between a lawyer and client;
    • Professional secrecy applicable to notaries and bailiffs;
    • The secrecy of judicial deliberations;
    • Rules governing criminal proceedings.

What can be reported?

You are encouraged to report any suspected misconduct, unethical behavior, or unlawful activity.

Examples include (non-exhaustive list):

  • Breaches of public procurement or state aid rules;
  • Bribery, fraud, corruption, or other financial misconduct;
  • Cybersecurity incidents and data protection breaches;
  • Environmental, health, and safety concerns;
  • Conflicts of interest;
  • Any breach of applicable EU or Luxembourg laws relevant to LIH’s activities.

How to report

Confidential and available 24/7

To ensure confidentiality and security, LIH has partnered with Whistlelink, an independent third-party provider of whistleblowing services.

Access the Whistlelink Reporting Platform here (available 24/7 in English, French and German).

Through the platform, you can:

  • Submit a written report securely;
  • Attach supporting documents, images, or other evidence;
  • Submit voice recordings, which are anonymized upon submission and processed in accordance with applicable legal requirements.

What happens after you submit a report?

1. Acknowledgement of receipt
You will receive confirmation that your report has been received within seven (7) days.

2. Assessment and investigation
The report will be reviewed by LIH’s Compliance Committee, which may seek support from external experts when necessary.

3. Feedback
You will receive feedback on the outcome or follow-up measures taken within a reasonable timeframe and no later than three (3) months after acknowledgment of receipt.

4. Protection against retaliation
LIH strictly prohibits any form of retaliation against individuals who report concerns in good faith. Retaliatory actions may lead to disciplinary measures and, where applicable, legal consequences.

Your rights as a reporting person

When making a report, you have the right:

  • To receive timely information regarding the progress and outcome of your report;
  • To have your identity kept confidential and disclosed only where required by law and subject to appropriate safeguards;
  • To be protected against retaliation, including where a report was made anonymously and in good faith.

Speak Up

Reporting concerns helps LIH maintain a culture of integrity, comply with legal obligations, and protect the interests of our employees, partners, patients, research participants, and society as a whole.

If you become aware of a potential breach, we encourage you to report it.

Access the Whistlelink Reporting Platform

(available 24/7 in English, French and German)

LIH Whistlelink platform