Before filing a report, please read the detailed information on whistleblowing at CEU below. For German and Hungarian translations and to file a report, click on the following link: https://whistleblowing.ceu.edu.
CEU consists of various legal entities in different jurisdictions, therefore different legal regimes apply depending on the location of the entity you are affiliated with. In the following, we will indicate the differences between jurisdictions where relevant.
1. What is Whistleblowing?
Whistleblowing is the act of reporting instances of misconduct or violations of the law, which have the potential to inflict significant harm on a company. Such damage may include tarnishing the company's reputation and incurring financial losses. By promptly reporting these suspicions, the severity of this damage can be minimized or even prevented altogether. At CEU, we wholeheartedly endorse and appreciate this vital practice.
To ensure fairness and transparency, we have established an internal reporting platform that guarantees a just process for all involved individuals. This Whistleblowing platform serves as a secure channel to facilitate filing reports and encourages accountability within our organization.
We recognize that whistleblowing plays a crucial role in maintaining the integrity and ethical standards of our institution. By fostering a culture that values and supports reporting misconduct, we aim to create an environment where concerns can be addressed effectively.
2. Who can file a report?
Reports may be submitted by individuals who have obtained information about legal violations due to their current or former professional affiliation to Central European University Private University – CEU GmbH (“CEU PU”), Közép-európai Egyetem (“KEE”) or CEU Oktatási-Szolgáltató Nonprofit Kft. (“CEU OSZ”):
- employees of the respective legal entity, including those provided as temporary staff, or
- applicants for a position, interns, trainees, or other individuals undergoing professional training at the legal entity (this does not include students at CEU), or
- self-employed individuals (contractors), or
- members of an administrative, executive, or supervisory body of the legal entity, or
- individuals who, work or have worked under the supervision and direction of a contractor, subcontractor, or supplier
In principle, an individual may only file a report for the legal entity of CEU the individual is affiliated with. However, individuals with 'shared contracts' may submit reports for all legal entities with which they are thus associated.
3. What can be reported?
a. Individuals affiliated with CEU PU in Austria within the meaning of section 2. may file reports for violations only in the following specific areas of law:
- Misappropriation of and fraud related to EU funding
- Corporate tax
- EU law on competition
- EU law on State aid
- Corruption
- Consumer Protection
- Environmental Damage
- Financial Services, Products and Markets, and Prevention of Money Laundering and Terrorist Financing
- Food and Feed Safety, Animal Health and Animal Welfare
- Nuclear Safety
- Product Safety and Compliance
- Protection of Privacy and Personal Data, and Security of Network and Information Systems
- Public Health
- Public Procurement
- Transport Safety
b. Individuals affiliated with KEE or CEU OSZ in Hungary within the meaning of section 2. may file reports for any illegal or suspected illegal acts or omissions or other misconducts. However, the protections for whistleblowers as mentioned in sections 12. (waiver of confidentiality) and 14. (protection against retaliation) below only apply, if (i) the reported information falls within the scope of the legal acts of the European Union listed in Annex 1 or Annex 2 of the Act XXV of 2023 on Complaints, Notifications of Public Interest and the Rules for Whistleblowing (“Complaints Act”) or legal provisions ensuring their implementation or compliance; or (ii) the whistleblower has reasonable grounds to believe that the circumstances referred to in point (i) exist.
4. How does the platform work?
On the landing page (https://whistleblowing.ceu.edu), you will be prompted to select the specific CEU entity location you are affiliated with and for which you wish to file a report, choosing between Austria or Hungary (if you choose any other country, you won’t be able to file a report), as well as the location where the incident took place. Provide a detailed description of the incident and complete the intake form accordingly. After submitting your report, you will be provided with a unique access number, and you will need to set a password for your account. You will be able to communicate securely and confidentially with the CEU Legal Office through your account and make changes to your report.
5. Can I file a report anonymously?
Yes, you have the option to file a report anonymously. However, we encourage you to consider identifying yourself when making a report. Investigating anonymous reports can be more challenging, and in some cases, it may even be impossible to proceed with an investigation without the necessary information or clarifications that identifying yourself can provide.
6. Can my identity be discovered?
You are in total control of the content of the message you leave: if you do not provide your contact details, CEU will not know who you are.
7. Can CEU trace my connection data?
No, CEU has no access to the connection data. IP-addresses will not be handed over to CEU. All data is encrypted and stored on the OneTrust servers based in Germany.
8. What kind of data will be processed and where can I find more information?
Details and involved parties, date, location, photo or file, e-mail, status of relationship to CEU. For non-anonymous reports additionally: Name and phone number (mandatory).
Note for anonymous reports: Your email address will not be shared with CEU or data processor staff, it will only be used by the system to send you emails. We recommend that you do not use your work email address. You can find more information in the privacy notice at www.ceu.edu/privacy.
9. How will my confidentiality be protected if I choose to disclose my identity?
Every report will be treated confidentially. This means your identity may be disclosed only to those people who need the information to investigate and resolve your allegation, or where another law or policy requires disclosure (for example a court subpoena or criminal investigation).
10. Can I submit documents?
Yes, the platform allows you to attach electronic documents to your report. However, if you prefer to remain anonymous, it is important to ensure that your contact details are not mentioned in the attachments or in their properties.
11. What if I don't remember my access number?
If you have misplaced or forgotten your access number, we kindly request that you submit a new report and indicate which previously submitted report (the one you forgot/lost your access number for) you are referring to, by providing us with the (approximate) date of submittal and a short summary of the case facts. Please make sure to use the new access number for any future communication regarding your report.
12. Will filing a report breach my confidentiality / non-disclosure agreement?
No, if the report has been made lawfully, meaning based on the circumstances and available information you had reasonable grounds to believe (i) that the report you gave is true and a violation of applicable laws (see section 3.) has occurred and (ii) that the report is necessary to disclose or prevent a violation of the law. If these requirements are met, the reporter is not considered to have breached any restriction on disclosure of a legally protected secret or any other legal restriction on disclosure of information and is not liable in respect of such a report. If a report has been lawfully made, the whistleblower is not liable for obtaining or having access to the information contained in the report, unless the whistleblower has committed a criminal offence by obtaining or having access to the information. These protections also apply to individuals that support a whistleblower, but don’t file a report themselves.
13. What happens once I file a report?
The Whistleblowing team at CEU’s Legal Office will diligently review and evaluate the information provided in your report. If your initial report lacks sufficient information or evidence, we will contact you to request additional details or evidence. An investigation will be opened if your report contains the minimum actionable information and evidence required. Rest assured that any investigation stemming from your report will be conducted in a professional and confidential manner. Only individuals necessary for addressing the specific matter at hand will be involved.
a. If you are affiliated with CEU PU within the meaning of section 2.:
Within one week of submitting your report, you will receive a confirmation on your account, acknowledging that we have received your report. Within a period of three months from the date of your initial report, you will receive an update on whether any subsequent actions have been taken or will be taken or the grounds for the discontinuation of the investigation.
b. If you are affiliated with KEE or CEU OSZ within the meaning of section 2.:
You will receive a confirmation on your account within seven days, acknowledging that we have received your report, which confirmation will contain procedural and data management information required by the Hungarian Act. We will investigate the allegations contained in the report within the shortest time possible, but not later than thirty days from the receipt of the report. The initial thirty days deadline can be extended under specific circumstances, but the length of the procedure may not exceed three months. Within the respective deadline we will inform you of the outcome of the investigation: if we have had to take action to remedy the unlawful/suspected unlawful acts, if we have had to initiate criminal proceedings, or if the investigation has not revealed any illegalities.
Please note that in certain cases, as provided by law (eg obvious false reports, reports without any hint of cogency), reports are not investigated further. If such case should arise, reporters will be informed.
14. Will I be retaliated against because of filing a report?
No, at CEU we are committed to upholding your rights as mandated by the law and will not tolerate any sanctions or retaliation against you because of lawful reporting.
A report is considered lawful when based on the circumstances and available information you had reasonable grounds to believe that the report you gave is true and a violation of applicable laws mentioned in section 3. has occurred. These protections also apply to individuals that support a whistleblower, but don’t file a report themselves.
15. What happens if the content of the report proves to be incorrect at a later point in time?
The key factor is that based on the circumstances and available information you had reasonable grounds to believe that the report you have submitted is true and that a violation of law within the meaning of section 3. has occurred. You are not expected to gather evidence or resolve the situation on your own. CEU's Legal Office will supervise and coordinate the investigation process. It is possible that the investigation may determine that no violation of the law has occurred. Again, in such cases, you need not worry about facing any negative consequences if the report was filed in good faith, as described in the first sentence.
16. What happens if I am falsely accused?
We are committed to conducting thorough of all reports, ensuring a fair investigation process. It is crucial that only reports made in good faith are filed. This means that based on the circumstances and available information the reporter had reasonable grounds to believe that the submitted report is true and that a violation of law within the meaning of section 3 has occurred. CEU maintains a strict policy of addressing allegations made maliciously or in bad faith. Such allegations will be subject to appropriate sanctions. At the same time, CEU is dedicated to protecting individuals from any adverse consequences who have been falsely accused.
17. What are alternatives to the internal whistleblowing platform?
a. If you are affiliated with CEU PU within the meaning of section 2.:
In Austria the Federal Office for Corruption Prevention and Corruption Control (BAK; https://www.bak.gv.at/) is responsible for providing an external whistleblowing channel. However, whistleblowers should primarily use the internal reporting system before turning to external authorities. The external authority assumes responsibility when utilizing the internal reporting system is not feasible, suitable, reasonable, or has proven to be futile. This external reporting channel can also be relevant for employees of legal entities that, due to their small number of employees, are not obligated to establish an internal reporting system.
b. If you are affiliated with KEE or CEU OSZ within the meaning of section 2.:
In Hungary you can file your report through several other channels:
One of the possibilities is to submit your report as a complaint or a public interest report to the Hungarian state or local authorities. A complaint is a request for redress for a violation of an individual right or interest, which is not subject to any other procedure, in particular judicial or administrative. The complaint may also contain a proposal. A public interest report draws attention to a situation, when the remedy or removal of this situation is in the interest of the community or society as a whole. A public interest report may also contain a proposal.
You can file a public interest report in your own name or without identifying yourself using the secure Hungarian electronic system for public interest reporting (https://www.ajbh.hu/kozerdeku-bejelentes-benyujtasa). The Commissioner for Fundamental Rights is responsible for the operation of the electronic system for submitting and registering reports of public interest.
Section 32(1) of the Hungarian Act XXV of 2023 on Complaints, Notifications of Public Interest and the Rules for Whistleblowing (herein “Complaints Act”) furthermore specifies the public bodies that will establish a separate whistleblowing platform from the above-mentioned ones. Anyone may also report to these separate platforms.
Whistleblowers have the same protection while using these external platforms as when filing through the internal platform (see section 12. and 14.).
18. Further information
For further information, the main national and EU legislation on the subject is linked below:
a. European Union: Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32019L1937
b. Austria: HinweisgeberInnenschutzgesetz – HSchG
c. Hungary: Act XXV of 2023 on Complaints, Notifications of Public Interest and the Rules for Whistleblowing (“Complaints Act”): https://njt.hu/jogszabaly/2023-25-00-00