In accordance with its values and Code of Business Conduct, the Pernod Ricard Group is uncompromising in its integrity and undertakes to conduct its business in strict compliance with applicable laws and high ethical standards. The whistleblowing scheme described below is open to all Pernod Ricard employees and temporary staff.
Pernod Ricard therefore encourages you to speak up about any practice or situation that they believe to be contrary or incompatible with our Code of Business Conduct, policies, standards, or the law, using the channel you are most comfortable with.
This could be your hierarchy, a member of your legal or human resources department in the first instance, especially when it comes to issues related to local working conditions such as conflicts with colleagues and managers or disciplinary sanctions.
As an alternative to internal process, the Pernod Ricard Group has implemented an ethics alert line hosted by an independent company (NAVEX). Speak Up is available 24/7, and can receive calls in most languages. It is aimed at allowing Pernod Ricard employees and temporary staff to report serious or sensitive situations where they have personal knowledge of facts, while ensuring that their concerns are addressed appropriately and in confidence.
Any concern about our business conduct, compliance and ethics matters or any breach or suspected breach of our Code of Business Conduct, legal, accounting or regulatory requirements, policies and standards, can be reported through Speak Up.
All reports must be made in good faith and not for personal interest.
“Good faith" means that at the time you provided it, you believed that the information you provided was complete, honest and accurate, even if it later appeared that it was an error. If you realize after reporting that you have made a mistake, you should immediately share that information using the same channel.
"Absence of personal interest" means that you should not expect any form of reward for having reported your concern.
Regardless of the reporting channel used, Pernod Ricard will take the necessary measures to preserve the confidentiality of your identity, the identity of the persons covered by the alert and the information contained in the alert. Only those persons responsible for collecting, processing and investigating the alert will have access to this information. These persons are bound by an obligation of confidentiality.
Speak Up is hosted on NAVEX's secure servers and is not part of the Pernod Ricard website or intranet. NAVEX does not track phone calls, does not use features such as caller ID, and does not link your IP address if you report online.
Your identity cannot be disclosed without your prior consent. If the confidentiality protecting your identity makes it impossible to process the report, you will be informed.
Elements likely to identify the person implicated by an alert may only be disclosed if the alert is established to be well-founded.
The confidentiality described above does not apply vis-à-vis judicial authorities.
We strongly encourage whistleblowers to identify themselves. However, you may remain anonymous in countries where it is legally permitted and provided that the seriousness of the facts is established, and the facts sufficiently detailed. Anonymity makes it more difficult to investigate and act on a reported problem, therefore providing your contact information can help an investigation. If anonymity makes it impossible to process your report or if you are in a country with restrictions on anonymous reports, you will be informed.
Although slanderous or bad faith accusations may give rise to sanctions, Pernod Ricard has zero-tolerance towards retaliation against anyone who has reported an allegation or supported an investigation in good faith.
Retaliation can take many forms. Direct retaliation includes unfair disciplinary procedures (including warning, demotion or termination), direct threat, harassment, unfair treatment or discrimination, unwarranted negative performance appraisal, change to an unwanted job, removal of benefits or trainings. Indirect retaliation could also be characterized by isolation from the team, exclusion from meetings or discussions important to advancement or performance, hostile work environment or exclusion from promotion or new opportunities.
Any form of retaliation will be treated very seriously and may result in disciplinary sanctions. If you witness or are subject to retaliation, you should report it to your Legal, HR, Chief Compliance Officer or to Speak Up, providing as much information as possible.
Through Speak Up, Pernod Ricard offers the possibility to report by telephone via a dedicated number specific to your country, or by drawing up an online report. Both options are available at: www.pernodricardspeakup.ethicspoint.com. If you need any assistance do not hesitate to ask your direct manager or your Legal Department.
Regardless of the communication channel used, you must, in all circumstances, provide all the information and documents at your disposal (whatever their form and nature) to support your alert. We also encourage you to share all information that will allow us to exchange with you.
If you call Speak Up, you will hear a recorded message in English or you can select to hear it in your local language (if applicable). The operator will then speak to you in the selected language, but interpreters can be arranged if you need them. Please be aware that for less widely-spoken languages, there may be a delay whilst you wait for an interpreter.
The operator will ask you which company you are calling about. They will read you a short data privacy statement about how the information you provide will be used. You will need to verbally agree to this to be able to proceed.
You will then be asked a series of standard questions to help us understand the exact nature of the concern or issue you are reporting. The more information you provide, the easier it is for us to investigate.
Online reporting is available in many languages. You will be directed to an online form to provide details about your concerns. The questions asked on the form are the same as the questions asked by the operator for phone alerts.
Once you have communicated your concerns by phone or online, you will receive a key and password that can be used to follow progress of your report. You can use it to track your case, add more information and answer any questions the investigator may have. You will be notified that your alert has been received and will be provided with an estimation of the time necessary to give you a preliminary answer on admissibility of the alert. You will then be informed regularly of the action taken on your report, via Speak Up.
Your report will be received by a committee composed of representatives of Pernod Ricard SA from the Legal, Internal Audit, Human Resources and CSR functions (the "Integrity Committee").
The Integrity Committee will review your report, assess its seriousness and credibility and determine the action to be taken. Investigations may be entrusted to appropriate persons at regional or affiliate level. The Integrity Committee or the investigators may also seek the services of external auditors, investigators and/or legal advisers to assist it in its investigation and in the analysis of the results thereof. The findings of the investigation will be forwarded to the Integrity Committee, which will validate the investigators' proposed outcome.
Any reporting will be handled fairly and in accordance with applicable local legislation. In particular, the defendant may be informed of the nature of the allegations concerning him within the limits of the confidentiality obligations described above. The information may not be immediate if it proves necessary, for example, to verify the facts, preserve evidence or inform relevant authorities.
During an investigation following a report, everyone should cooperate fully and provide without delay all information and documents.
Any person who has made a report, or is the subject of a report, will be informed of the results of the process, to the extent that this is both appropriate and that information can be communicated without breaching the law or other confidentiality obligations.
Where, at the end of the verification operations, no action is taken on the alert, the file will be closed. If necessary, Pernod Ricard will destroy, within two (2) months following such closure, or any other applicable duration period, the information relating to the alert in question. The person(s) who issued the alert and the person(s) to whom the alert relates shall be informed of such closure and of the destruction of the related items.
Where action, for example disciplinary or legal, is taken on the report, including against a person who has made false accusations, the information may be retained for the purpose of such action.
Where the issue reported is out of the scope of what can be reported through Speak Up, Pernod Ricard will delete or archive the information.
The archived information is stored within NAVEX’s secure servers located in the EU for a period that will not exceed the applicable data retention period.
The personal data processed through Speak Up will be collected, processed and stored in compliance with applicable data protection laws and further to the Data Protection and Privacy Notice.
Any request related to data protection and privacy should be sent to the Data Protection Officer by email at groupdpo@pernod-ricard.com.