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Article 19 of the ZZPri lists examples of retaliation that an employer may impose on a reporting person/whistleblower for filing a report:

  • termination of employment;
  • suspension of employment contract;
  • demotion, preventing or withholding of promotion;
  • transfer of duties, change of location of place of work, change in working hours, reduction of work obligations, non-payment and reduction of wages and other allowances, non-payment of bonuses and termination benefits;
  • preventing or withholding of education and professional training;
  • negative performance assessment, poor annual appraisal or negative employment reference;
  • imposition of disciplinary proceedings, imposing disciplinary measures or penalties;
  • bullying, coercion, intimidation, harassment or exclusion, and lack of dignity protection against such conduct by other persons;
  • discrimination, disadvantageous or unfair treatment;
  • failure to conclude a fixed-term employment contract when the conditions laid down by law for concluding a fixed-term contract have been met;
  • termination of a fixed-term contract before the expiry of the fixed-term contract or before the end of the reason for concluding the fixed-term contract;
  • other arbitrary conduct by the employer, including actions that cause damage, even to the reputation of an individual, especially on social networks, financial loss, including loss of business and loss of income;
  • early termination or cancellation of a contract for the purchase of goods or services, or other termination of a business partnership;
  • the cancellation, temporary suspension or permanent revocation of a licence or permit;
  • arbitrarily ordering of a medical examination or fitness-for-duty assessments;
  • blacklisting on the basis of a sector or industry-wide informal or formal agreement, resulting in the reporting person's inability to find new employment in the industry or sector;
  • initiating malicious proceedings against the reporting person;
  • threatening or attempting to retaliate.


Part of providing relevant information to the reporting person may also include the fact that the threat of retaliation, attempted retaliation or retaliation itself is defined as a minor offence in Section 9 of the ZZPri (Minor offence authorities and penal provisions). The external reporting authorities are responsible for conducting and deciding on minor offence proceedings under the ZZPri.


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