The Klépierre Whistleblowing Platform is a tool designed to receive and process reports of misconduct involving Klépierre employees and business partners, while fostering a positive work and business environment.
The Klépierre Whistleblowing Platform is owned and operated by NAVEX, independently from Klépierre.
NAVEX is an independent company selected by Klépierre to provide secure, confidential, web-based systems for use by Klépierre’s employees, customers, suppliers and other stakeholders who wish to make a report.
It is not NAVEX’s role to take action to address the concern, but only to transmit the report to designated personnel at Klépierre as required to investigate (“coordinators”).
Klépierre is providing the Whistleblowing Platform through NAVEX’s Incident Management solution. Your personal data is collected and processed in accordance with the Klépierre Whistleblowing Platform Data Protection Charter. The NAVEX Privacy Statement is only applicable to the extent that NAVEX collects personal data through cookies and other similar technologies on its NAVEX Incident Management platform. In that case, NAVEX is solely responsible for such data collected on their website and for complying with applicable laws.
The Klépierre Whistleblowing Platform is important because integrity, fairness and accountability matter to Klépierre. The Klépierre Code of conduct gathers Klépierre’s internal rules which aim at maintaining fair and trustworthy relationships with its customers, suppliers and other stakeholders.
The Klépierre Whistleblowing Platform provides an easy way for you to get in touch with Klépierre if you see, hear or suspect that something is not right in your interactions with the Group, its employees, customers, suppliers, or other stakeholders. There shall be no retaliation from Klépierre against you for raising a possible concern and you may choose to remain anonymous in most cases (unless otherwise required by law in your location).
Any concern about our business conduct and ethics, compliance and any breach or suspected breach of our Codes and Charters, legal, accounting or regulatory requirements, policies and standards, can be reported through the Klépierre Whistleblowing Platform.
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.
Through its Whistleblowing Platform, Klépierre offers the possibility to report by telephone (local call cost) or by filing a report online.
If you work at Klépierre and need any assistance, do not hesitate to contact your Compliance Officer or the Group Risk management department.
If you need assistance and do not work at Klépierre, you can send an email to ethics-compliance@klepierre.com.
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 substantiate your report. You are also encouraged to share all information that will allow Klépierre to exchange with you.
Online reports
Online reporting is available in many languages. You will be directed to an online form to provide details about your concerns.
Phone reports
If you call the Whistleblowing Platform, you will hear a recorded message in English and have the option to switch to your local language (if available). Based on your selection, the operator will then speak to you in the language selected.
If you are unable to find a specialist who speaks your language while selecting the language in the in-call menu, an interpreter can be arranged if you need. The interpreter thus will act as a bridge between you and the specialist and help you complete your report. Please be aware that for rare languages, there may be a longer waiting time before connecting to the 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 proceed.
You will then be asked a series of standard questions on the exact nature of your concern or the issue you are reporting. The more information you provide, the easier it will be for Klépierre to investigate.
QR Code
To file a report using personal devices, notably mobile devices, a QR code is available to access the Klépierre Whistleblowing Platform. The declaration form for mobile device is a streamlined version for a much more efficient way to declare.
Once you have communicated your concerns online or via QR code, 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 the Whistleblowing Platform.
This site is not meant to report events presenting an immediate threat to life or property. Reports submitted through this service may not receive an immediate response. If you require emergency assistance, please contact your local emergency services.
When you observe some behavior that you believe violates Klépierre’s Codes or Charters, or any other internal rule, the law and business ethics, you should report it. Ideally, you should bring any concerns forward to your direct manager, or other member of our management team. There may however be circumstances when you are not comfortable reporting the issue in this manner. It is for such circumstances that Klépierre has partnered with NAVEX. It is preferable that you report anonymously than keep the information to yourself.
We all have the right to work in a positive environment. With that right comes the responsibility of acting in an ethical manner and letting the appropriate people know if someone is not acting appropriately. By working together, we can maintain a healthy and productive environment.
Certainly so! Klépierre needs you to report. You may have initial knowledge of an activity that may be cause for concern. Your reporting can minimize the potential negative impact on the Group and its people. Also, offering positive input may help identify issues that can improve corporate culture and performance.
Never assume another employee has reported the violation or concern. Unless the potential issue is reported, Klépierre may remain unaware of the conduct. Klépierre depends on you to timely report any instances of misconduct or inappropriate behavior you become aware of.
Reports are entered directly to a secure, third-party server to prevent any possible breach in security.
The reports are only available to specific individuals at Klépierre (the Group Coordinators or Local Coordinators, see the chart on the homepage) who are responsible for evaluating the report. These individuals have a duty of keeping these reports in the utmost confidence.
The purpose of the Klépierre Alert Platform is to enable Klépierre to ensure a safe, secure and ethical working environment. You are encouraged to seek guidance on ethical dilemmas, provide positive suggestions, or communicate a concern.
Effective communication is critical in today’s workplace, and this is a great tool to enhance that communication.
We have carefully chosen the best reporting tool to meet our compliance obligations while maintaining a positive reporting environment.
The Klépierre Whistleblowing Platform is a system designed for you to declare any behavior that goes against the applicable legal norms, Klépierre’s internal rules, values and moral bounds.
The Klépierre Whistleblowing Platform is a declarative mechanism and is not designed to neither monitor nor survey the actions of an individual and/or a department. Klépierre does not possess or engage technologies that track or monitor an individual and operates in the bounds of the law. Klépierre Whistleblowing Platform ensures your anonymity if you choose to stay anonymous, protects you from retaliation and encourages a clean, safe and ethical working environment.
The system enables the Coordinator who reviewed your report to post questions for you, even if you report anonymously (via the anonymous key given to you at the time of filing your report).
If the telephone number is not functioning, please make your report online through this website. Please indicate in the report that the telephone number did not work.
If you do not see your country in the list, please make your report online. Please select the location “Others” and precise your country in the form.
To enable the Coordinators to conduct their investigation, you must contribute with full transparency and respond to their inquiries.
Coordinators are bound by strict ethical and confidentiality obligations.
Depending on the severity of the concern and what the review has revealed, outcomes can range from no action at all to, for instance: education and coaching, disciplinary action, department re-organization, process redesigning, adapting new policies and codes, business or employment contracts termination or legal actions.
Please note that the information you provide may result in decisions that affect other Klépierre employees or third parties involved in the relevant incident.
We, therefore, ask you to provide only information that, to the best of your knowledge, is accurate and relevant to the report.
You will not be subject to retaliation from Klépierre for any report that is made in good faith, even if it later turns out to be incorrect. However, knowingly providing inaccurate or misleading information will not be tolerated and may result in disciplinary action or judicial proceedings.
The Klépierre Whistleblowing Platform does not generate or maintain any internal connection logs with IP addresses, so no information linking your computer to the Klépierre Whistleblowing Platform is available.
NAVEX (which is the third-party service provider managing the Klépierre Whistleblowing Platform) is contractually committed not to pursue a reporter’s identity.
Nevertheless, if you feel uncomfortable making a report accessing the Klépierre Whistleblowing Platform secure website through your professional computer, you have the option of using a computer outside Klépierre’s work environment (such as one located at a media center, at a friend’s house, etc.) or a mobile device.
A report from home, a neighbor’s computer, or any Internet portal will remain secure and anonymous, where permitted by local laws. An Internet portal never identifies a visitor by screen name and the NAVEX system strips away identifying information, such as an IP address, so that anonymity is maintained. Also, the NAVEX administrators are contractually committed not to track a reporter’s identity.
A more complete and thorough investigation can be conducted if you identify yourself and those involved because it allows the Coordinators to directly follow up with you and others, as well as provide updates throughout the investigation process.
If you choose to identify yourself when reporting your concern, Klépierre will make every reasonable effort to hold your name in confidence during the investigation.
If you decide to report anonymously, the NAVEX system will protect your anonymity. 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.
The NAVEX system will not track or log your IP address, or other identifying information.
Because of the high level of confidentiality that is maintained for reports, if you lose your report key or password, you will be required to file a new report. Please mention in the new report that this matter relates to a previously filed report.
Yes. You will be asked to provide the same information that you would provide in an online-based report and an interviewer will type your responses into the NAVEX website. These reports have the same security and confidentiality measures applied to them during the whole process.
Klépierre chooses to promote ethical behavior. All unethical conduct, at any level, ultimately can hurt the Klépierre group in its entirety and can have disastrous effects that a seemingly harmless lapse in ethics can have on an otherwise healthy company. So, if you know of any incidents of misconduct or ethical violations, consider it your duty, and that of your colleagues, to report it.
The system and report distribution protocols are designed so that implicated parties are not notified about or granted access to reports in which they have been named.
File a report. We had rather you report a situation that turns out to be harmless than let possibly inappropriate behavior go unchecked because you were not sure.
All reports should be made without malice or consideration of personal benefit and the reporting individual should have a reasonable basis for believing the report to be credible.
When you file a report, you will receive a unique report key and will be asked to choose a password. You can always return to the NAVEX system and access the original report to add more detail, answer questions posed by a Coordinator, or add further information that will help resolve open questions. We strongly suggest that you answer follow-up questions as this will allow the investigation team to properly assess the suspected violation.
When filing the report, include all information that you believe would be pertinent to the investigation, including individuals involved, timing/date of the violation, any relevant documentation/attachments, detailed description of the incident, and any other relevant information that would help the Coordinators conduct a thorough review of the report.
All NAVEX correspondence is held in the same strict confidence as the initial report.
Yes. All correspondence is held in the same confidence as the initial report. You can continue to remain anonymous, if you so choose and wherever permitted by local law.