Frequently Asked Questions (FAQ)

About Speak up! & EthicsPoint

Reporting - General

Reporting via the Helpdesk - General

Reporting via the Helpdesk - Security & Confidentiality

About Speak up! & EthicsPoint

What is Speak up!?

Speak up! is Imerys global program for reporting wrongdoing in the workplace. It enables management and employees to address fraud, abuse and other misconduct in the workplace while cultivating a positive work environment and fostering a culture of integrity.

At Imerys, there are two open channels of communication to report wrongdoing: via a member of the management team or a dedicated helpdesk (internet or telephone).

What is EthicsPoint?

EthicsPoint is the name of the dedicated helpdesk (internet and telephone) administered by a company called NAVEX.

Reporting – General

What types of situations should I report?

Speak up! encourages anyone to report concerns about violations of the Imerys Code of Business Conduct & Ethics or applicable laws and regulations. This includes threats to safety or health, fraud, damages to environment, bribery, conflicts of interest, discrimination, harassment, anticompetitive practices, and violations of human rights.

If I see misconduct, shouldn't I just report it to my manager or human resources and let them deal with it?

When you observe some behavior that you believe violates our Code of Business Conduct & Ethics or applicable laws and regulations, we expect you to report it. Ideally, you should bring any concerns forward to your line manager or other member of your management team or the relevant support function. However we recognize that there may be circumstances when you are not comfortable reporting the issue in this manner. It is for such circumstances that we have partnered with NAVEX, using their dedicated helpdesk EthicsPoint. We would rather you report via this confidential helpdesk (and anonymously if you choose to) than keep the information to yourself.

I am aware of some individuals acting unethically, but it doesn't affect me. Why should I bother reporting it?

Imerys promotes ethical behavior. All unethical conduct, at any level, ultimately hurts the Group and all employees, including you. You only have to consider what happened in recent corporate scandals to see the disastrous effects that a lapse in ethics can have on an otherwise healthy company. If you know of any incidents of misconduct or ethical violations, consider it your duty to yourself and your coworkers to report it.

Does management really want me to report?

We certainly do. In fact, we need you to report. You know what is going on in our company - both good and bad. You may have initial knowledge of an activity that may be cause for concern. Your reporting can minimize the potential negative impact on the company and our people.

I am not sure if what I have observed or heard is a violation of Group policy, or involves unethical conduct, but it just does not look right to me. What should I do?

Report your concern. You should bring any concerns forward to your line manager or other member of your management team or the relevant support function. However we recognize that there may be circumstances when you are not comfortable reporting the issue in this manner. It is for such circumstances that we have set up a dedicated helpdesk (EthicsPoint) administered by NAVEX. We'd rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked.

Reporting via the Helpdesk - General

What types of situations should I report via the helpdesk?

Speak up! encourages anyone to report concerns about violations of the Imerys Code of Business Conduct & Ethics or applicable laws and regulations. This includes threats to safety or health, fraud, damages to environment, bribery, conflicts of interest, discrimination, harassment, anticompetitive practices, and violations of human rights.

The helpdesk is NOT meant to report minor concerns such as disagreements on some management decisions.

The helpdesk is NOT an emergency service. Do not use this site 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 authorities.

May I report using either the internet or the telephone?

Yes. This helpdesk enables you to file a confidential report via either the internet or the telephone.

What happens after I contact the helpdesk?

Once you submit a concern via web or phone, you will receive a Report Key and password which can be used to follow up on your report. Then, an electronic summary is sent to the Imerys whistleblowing central referents for review and to determine further action.

What if I lose my Report Key or forget the password I created?

To ensure that security and confidentiality are 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 you previously submitted.

What if I remember something important about the incident after I file the report? Or what if Imerys has further questions for me concerning my report?

When you file a report online or through the call center, you receive a unique, randomized number called a “Report Key” and are asked to choose a password. You can return to the system again either by internet or telephone and access the original report to add more detail or answer questions posed by a company representative. We strongly suggest that you return to the site in the time specified to answer company questions. You and the company representative now have entered into a “confidential dialogue,” where situations are not only identified, but can also be resolved, no matter how complex.

Can I still file a report if I don’t have access to the internet?

You can file a report online from any computer that can access the internet. You can file from home. Many public locations, including the public library, have internet computers. If you don’t have access to or are uncomfortable using a computer, you can call the toll-free hotline, which is available 24 hours a day, 365 days a year.

Isn’t this helpdesk just an example of someone watching over me?

No. This helpdesk is a positive aspect of our overall philosophy that allows us to ensure a safe, secure and ethical workplace. You are encouraged to seek guidance on ethical dilemmas, or communicate a concern. Effective communication is critical in today’s workplace and this is a great tool to enhance that communication.

Reporting via the Helpdesk - Security & Confidentiality

Can I file a report anonymously?

You can choose to make a report anonymously, except where legally restricted from doing so. In that case, you should not include information that may personally identify you.

However we encourage you to make a report by identifying yourself as it facilitates the investigation. Please note that Imerys takes no action in retaliation against any person for making a good faith report.

It is my understanding that any report I send from a company computer generates a server log that shows every website that my PC connects with. Won’t this log identify me as the report originator?

NAVEX 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 your work environment (such as one located at an Internet café or at a friend’s house) through the EthicsPoint secure website. Many people choose this option, as NAVEX’s data shows that fewer than 12% of reports are generated during business hours.

Can I file a report from home and still remain anonymous?

A report from home, a neighbor’s computer, or any internet portal will remain secure and anonymous. An internet portal never identifies a visitor by screen name and the EthicsPoint system strips away internet addresses so that anonymity is totally maintained.

I am concerned that the information I provide EthicsPoint will ultimately reveal my identity. How can you assure me that will not happen?

The EthicsPoint system protects 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. For example, “From my cube next to Jan Smith…” or “In my 33 years…”.

Is the telephone toll-free hotline confidential and anonymous too?

Yes. You will be asked to provide the same information that you would provide in an internet-based report and an interviewer will type your responses into the EthicsPoint website. These reports have the same security and confidentiality measures applied to them during delivery.

Where do these reports go? Who can access them?

Reports are entered directly on the EthicsPoint secure server. NAVEX makes these reports available only to specific individuals within the Imerys Group (referred to as the Imerys whistleblowing central referents) who are charged with evaluating the report, based on the type of violation and location of the incident. Each of these report recipients has had training in keeping these reports in the utmost confidence.

What if my boss or other managers are involved in a violation? Won’t they get the report and start a cover-up?

The EthicsPoint system and report distribution ensure that implicated parties are not notified or granted access to reports in which they have been named.

Are the follow-ups on reports as secure as the first one?

All EthicsPoint correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of confidentiality.