What is Whistleblowing

Whistleblowing indicates the contribution offered by internal or external to the Company subjects (whistleblower). It is designed to identify and manage the following issues:

  • Behaviours classified as crimes;
  • Alleged violations of the Triennial Anti-corruption and Transparency Plan (“PTPC”), the code of ethics, the collective agreement (CCNL), contractual obligations, …;
  • Alleged violations or evasion of management procedures and policies or any form of fraud in the internal control system;
  • Undisclosed conflict of interest that may affect the impartiality and the good performance of the Company/Institution.

The reported issue must be strictly related to the Company/Institution activity. It must be based on a clear knowledge of the facts and circumstances. Offensive, libellous, and defamatory reporting will not be taken into consideration, without prejudice to any action to protect the injured party. Please abstain from reporting in order to harm or defame colleagues.

The facts and circumstances that can be reported are (without being exhaustive):

  • Inappropriate use of the clock-in card (e.g. the employee clocks-in and does not present to work or clocks-in for absent colleagues; the employee leaves the office or carries out personal activities during working hours);
  • Receiving bribes from interested parties (e.g. suppliers, consultants, subsidy and utility recipients...), in violation with the Code of Ethics;
  • The assignment of work positions or supplies for economic personal interests, nepotism or without adequate disclosure by corporate subjects that are involved directly or indirectly in the decision-making process;
  • Inappropriate use or theft of company assets (e.g. cars, telephones, PC, sim cards…);
  • Administrative procedure fraud to unduly favour third parties;
  • Inducing or forcing suppliers/consultants/candidates to bribe for favours during negotiation procedures or in the selection process for the assignment of work positions;
  • Bribery from suppliers/consultants/candidates for favours during negotiation procedures or in the selection process for the assignment of work positions.