FAQs

As a Group, we’re committed to doing business in an ethical, legal and socially responsible way. But it’s possible you might come across a situation or behaviour that concerns you, or that seems to breach the law, our Code of Business Ethics & Conduct (Code), or any other Group policy.

If this happens, we encourage you to Speak Up, so we have the opportunity to deal with the situation or concern – and to support you, if you need us to.

Everyone working for or on behalf of the Group worldwide, including contractors, job applicants and former employees. As well as any person or party with whom the Group has, or had, a business relationship.

We support a Speak Up culture where everyone feels safe to raise and discuss any concerns. You can use various Speak Up channels (described in question below) to report concerns about possible misconduct or breaches of the law, our Code, or any other Group policy.

You can use the Speak Up channels to raise concerns about, for example, the following areas:

• Fraud
• Bribery or corruption
• Money laundering or terrorism financing violations
• Breaches of sanctions and export control laws
• Conflicts of interest
• Human rights violations
• Discrimination or harassment
• Breaches of competition laws and rules
• Breaches of privacy laws
• Inadequate financial and non-financial record keeping
• Environmental, health and safety violations
• Improper use of company resources
• Insider trading
• Misuse of confidential information
• Breaches of applicable law, our Code or any other Group policy
• Retaliation against anyone for Speaking Up.

The Speak Up channels should not be used:

• To report events that are an immediate threat to life or property. If you need emergency assistance, please contact your local authorities or call your country’s emergency phone number
• For grievances about your terms of employment
• For personal legal disputes
• For consumer complaints
• To make false accusations or to raise concerns other than in good faith.

You can raise concerns through a variety of channels, without replacing your regular reporting lines or complaints procedures within your business.

If you think that misconduct is happening, we encourage you to talk directly to the person involved. If this isn’t possible, or if you don’t feel comfortable, you can raise your concerns using these additional channels:

Speak Up channels within your business line:

• Your line manager: We encourage you to discuss your concern with your line manager. We know that’s not always easy, but we support an open and transparent approach
• HR: If you don’t feel you can talk to your line manager about the concern, you can discuss it with HR.

Speak Up channels outside your business line:

• Ethics & compliance officers: Local business and segment-level ethics & compliance officers, along with the Group Ethics & Compliance team, can give you confidential advice and support
• Speak Up Service (this website and associated telephone numbers): If you feel that your concern cannot be dealt with through any of the above channels, you can use the Speak Up Service.
  • This service allows you to raise concerns confidentially, anonymously (if necessary), and in your own language
  • The Speak Up Service is run by an independent provider and is available 24/7
  • The Group Ethics & Compliance team will get a transcript of your report and will be able to communicate with you confidentially via the Speak Up Service.

If you’re not a Group employee but you have, or had, a business relationship with the Group (eg as a supplier) and you wish to raise a concern, please contact your Group contact person. If this isn’t possible or you don’t feel comfortable, you can also contact the Group Ethics & Compliance team directly or use the Speak Up Service.

We encourage you to Speak Up as soon as possible; ideally when the potential misconduct or breach can still be prevented, and before the situation escalates. If you have reason to believe that misconduct or a breach has happened, or might happen, we encourage you to Speak Up with the facts that you know and the information you have.

We don’t expect you to have all the answers and we ask you not to investigate any concern yourself.

No matter which channel you use to Speak Up, please provide as much detailed information as you can, so we can respond in the best possible way.

We can only follow up a report if it contains enough information, or there’s a possibility of getting more details. Whether the report is investigated further will often depend on the amount of information you provide in your report. It may be difficult to follow up a case properly or investigate a concern if we only have limited information.

By Speaking Up internally, you’ll give us the opportunity to look into the matter, take necessary and appropriate action, and support you, if you need it.

If you raise your concern via the Speak Up Service (this website or associated telephone numbers), your report will be routed back to the Group Ethics & Compliance team for further handling and you’ll get confirmation of receipt within seven days.

When you submit your concern to the Speak Up Service, you’ll be given a unique code called a ‘report key’. You can use this key to call back or access the Speak Up Service website to check progress on your report.

Please note your report key for the Speak Up Service is particularly important if you choose to remain anonymous (where legally permitted), because we’ll only be able to contact you through the website.

To ensure that security and confidentiality is maintained, if you lose your report key or password, you will need to file a new report. Mention in the new report that it is related to a report or question you previously submitted.

We won’t tolerate any retaliation against anyone who, in good faith, makes a Speak Up report in line with the Group Speak Up policy. Concerns that are raised will be treated confidentially and, if desired and permitted under local law, anonymously.

Please remember that misusing the Speak Up channels is a violation of our Code and is not protected against retaliation under this policy. We consider misuse to be an extremely serious matter and it will result in disciplinary action.

If you feel that a matter you reported, or were involved in, hasn’t been properly investigated, or wasn’t handled in line with this policy, please contact the Group Ethics & Compliance team to discuss the options that you have (including the possibility of reporting the concern externally).

The EthicsPoint system is designed to protect your anonymity (if selected when reporting). However, if you wish to remain anonymous, you - as a reporting party need to ensure that the body of the report does not reveal your identity by accident. For example, “From my cube next to Jan Smit” or “In my 33 years…..”.

EthicsPoint does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to EthicsPoint is available. If you feel uncomfortable making a report on your work PC, you have the option of using a PC outside of our work environment. The internet portal never identifies a visitor by screen name and the EthicsPoint system strips away internet addresses so that anonymity is totally maintained.