Whistleblowing Mechanism - Alstef Group

Alstef Group’s Whistleblowing Mechanism

Alstef Group is committed to scrupulously complying with laws and regulations, and to enforcing the rules set out in the Group’s Anti-Corruption Code of Conduct.

The whistleblowing mechanism, available from this page, enables you to report information concerning a crime or misdemeanor, a threat or harm to the general interest, a violation or attempted concealment of a violation of applicable and binding law (laws, regulations, etc.) or a breach of the Group’s Anti-Corruption Code of Conduct.

Whistleblowers’ reports are treated confidentially and in accordance with applicable regulations.

Whistleblowers are protected against the risk of reprisals by the local legislation applicable to them.

Misuse of the mechanism may result in sanctions or prosecution.

Alstef Group may collect and process information and personal data concerning you in the course of collecting and processing your report.

The information collected in the ethical alert procedure, is processed for the purpose of collecting and processing alerts or reports aimed at revealing a breach of a specific rule, in accordance with European Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 “on the protection of individuals with regard to the processing of personal data and on the free movement of such data” (EU-GDPR).

 

FAQ

What is a whistleblowing mechanism?

A whistleblowing mechanism is a means made available to Alstef Group employees and stakeholders to report acts, behaviors or situations that may violate the integrity and/or rights of individuals, affect Alstef Group’s business or seriously engage its responsibility (corruption, harassment, health/safety, environment, etc…).

Can you send a report?

The Alstef Group whistleblowing system is intended for all Alstef Group employees and stakeholders who are victims or witnesses of a situation or behavior described below.

  • All Alstef Group employees, whatever their function, sector of activity or country;
  • All Alstef Group stakeholders: service providers, customers, suppliers, subcontractors, etc.
WHAT KIND OF REPORT CAN I SEND?

The Mechanism set up within the Alstef Group enables Employees to report in good faith (i) a criminal offence, a clear violation of applicable law or a threat or harm to the Group; and/or (ii) clear violations of the Alstef Group’s Anti-corruption Code of Conduct, the Supplier Ethics Charter and/or applicable laws and directives.

A crime or misdemeanour:

  • Corruption or influence peddling;
  • Money laundering/Falsification of books and records;
  • Misappropriation of assets;
  • Discrimination/Harassment;
  • Violation of social standards and employment law;
  • Undeclared work.

Violation or attempted concealment of a violation of:

  • An international commitment duly ratified or approved by France;
  • A unilateral act of an international organisation taken on the basis of such a commitment;
  • European Union law;
  • The law or the regulations.

Conduct or situations contrary to the Alstef Group’s Anti-Corruption Code of Conduct, insofar as they are likely to constitute corruption or influence peddling.

Remember:

  • Whistle-blowing must be done in good faith and without malice.
  • The warning must relate to any serious fact of which the whistle-blower has personal knowledge.
WHAT IS THE PROCESS FOR SUBMITTING A REPORT?

Whether you are an Alstef Group employee or stakeholder, please use the form available on this page.

HOW WILL MY REPORT BE HANDLED?

Once the report has been received, the Alstef Group Administrative and Financial Director or the Alstef Group Human Resources Director:

  • Acknowledges receipt within seven (7) days to the whistleblower and informs the whistleblower that the acknowledgement of receipt does not constitute acceptance of the report;
  • Informs the whistleblower, within 30 working days of receipt, whether or not the report is admissible. In the absence of a response within 30 days, the report is considered inadmissible;
  • If necessary, asks the whistleblower to add to the report if any information is missing;
    • Informs the whistleblower of the foreseeable and reasonable time required to investigate the case. The time taken to investigate the case must not exceed three (3) months;
  • Informs the whistleblower that the work information and documents provided may be used in the event of an internal investigation.
  • Following the investigation, a report will be issued. If the internal investigation shows that a member of staff has behaved in breach of the anti-corruption code of conduct, the appropriate disciplinary measures will be applied. In the absence of convincing facts, the alert is closed without further action.
Is my report confidential and anonymous?

We guarantee strict confidentiality and anonymity.

Confidentiality:

We respect the confidentiality of the identity of the whistle-blower, of the identity of the persons targeted by the alert, and of any documents transmitted in connection with the alert.

Please be aware that the people in charge of handling alerts are trained to handle reports confidentially, and as such take all appropriate and necessary measures.

Anonymity:

Your alert may be made anonymously, unless otherwise stipulated by law. In this case, Alstef Group undertakes to respect the whistleblower’s anonymity.

Nevertheless, we recommend that you provide information enabling the person in charge of processing the report to contact you.

What are my rights and protection as a whistleblower?

Protection:
No retaliatory measures (criminal or disciplinary) linked to the alert may be taken against the whistleblower.

However, any abusive or inappropriate use of the form may result in prosecution.

Rights:

Alstef Group guarantees the following rights to any person identified in the context of the System:
– Access to their personal data;
– Rectification of their data if it is inaccurate, incomplete, ambiguous or out of date;
– Refusal of the processing of personal data for legitimate reasons.

To find out more about your rights, click here.