It is essential to be able to identify breaches of ethics quickly.
Our whistleblowing platform allows employees and stakeholders (external staff, employees of service providers or subcontractors, suppliers, shareholders and representatives of civil society) to report any serious problems so that we can remedy them. These alerts may constitute a crime or an offense, a serious and manifest violation of the law or regulations, a threat to the general interest or a breach of the code of conduct, in particular the existence or risk of serious violations of human rights and fundamental freedoms, the health and safety of individuals and the environment.
Definition of a whistleblower and description of the facts
A natural person who reports or discloses, without financial compensation and in good faith, information relating to a crime, an offense, a threat or harm to the public interest, a violation or an attempt to conceal a violation of international or European Union law, or a violation of a law or regulation, will be recognized as a whistleblower
As such, the facts that are the subject of the report must be presented objectively and factually, showing their alleged nature, and present a direct link with the subject of the alert.
Protection of whistleblowers:
It is not always easy to file a report, which is why we have implemented a process designed to ensure strict confidentiality, impartial and diligent treatment, protection against retaliation and compliance with national legislation.
Anonymity: You have the option of remaining anonymous. In this case, do not provide any personal information.
Handling of alerts:
Alerts issued via this platform will be dealt with by the ethics committee, depending on the category.
If the person dealing with your alert is involved in the report, you can choose to:
- Contact your line manager
- Contact the ethics committee
- Make an external report (see External reporting)
Process:
Once a report has been registered on the platform, the persons authorized to process reports on the platform will proceed, in complete confidentiality, to verify the facts reported, in order to determine the admissibility of the report and to make an informed decision on how to proceed.
-------The author of the report will be kept informed of the processing of the alert via an anonymous online discussion area. This area also allows for clarification and exchange with case managers. Information regarding access to this area should be kept in a secure location.--------------------
The processing times are as follows:
● 7 days to acknowledge receipt of the report
● 90 days to process it
Data retention: If the allegations contained in the report are inaccurate or the report has become irrelevant, the report will be closed. The author of the report will be informed in writing of the closure of the file.
External reporting: any whistleblower may also submit an external report, either after having submitted an internal report or directly. The list of competent authorities is annexed to the decree (Article - Decree No. 2022-1284 of October 3, 2022, relating to the procedures for collecting and processing reports issued by whistleblowers and establishing the list of external authorities established by Law No. 2022-401 of March 21, 2022, aimed at improving the protection of whistleblowers - Légifrance (legifrance.gouv.fr), with the authorities being classified by field.
This system is hosted by a service provider who has no access to the data but guarantees its functioning.
----------I have lost my login details for my personalized space, what can I do? You can create a new report by explaining your situation and the report already made to the referent. The referent will then be able to communicate with you through the new communication space created ----------------
How our whistleblower system helps protect your privacy
- No identifying information is provided to the contacts.
- Your message will be stylometrically redacted to provide you with an even higher level of anonymity. We remove all punctuation and convert all words to lowercase.
- All information is end-to-end encrypted, so your sensitive information remains safe.
What you can do to protect yourself
- You are not on the corporate network (Internet/VPN).
- You should not use a device (smartphone, computer, etc) that is provided by your employer.
- You should not use the kinds of idioms or abbreviations that you frequently use in conversations or when writing emails.