About EthicsPoint
What’s whistleblowing
It’s an important way for detecting corruption, illegal or unethical behavior or other wrong conduct to avoid serious impact to the company's business or incur its liability, in an effort to give the company an opportunity to prevent them in time and correct them. The system also contributes to the protection of the Society at large.
Who may send a whistleblowing report?
The system applies to employees at all levels, corporate body, executive manager self-employed, paid and unpaid trainees, volunteers, but also former employees or prospective employees, contractors, subcontractors, suppliers, non-executive directors and shareholders.
What are the Whistleblower protections?
The identity of the Whistleblower, as well as any third party mentioned, must be treated with a high level of confidentially.
In addition, the identity of both the Whistleblower, as well as any third party mentioned, are protected. It also applies to relatives, dependents, or spouses of any of these people.
The reporting persons are protected from dismissal, degradation and other discrimination as well as retaliation actions (by example: Suspension, termination of contract, dismissal or equivalent measures…).
Reports must be made on factual basis, without any defamatory or prejudicial content.
What is EthicsPoint?
Candriam has put in place a whistleblowing platform, hosted by a third-party hotline provider, EthicsPoint. This platform allows you to report information about a crime or an offence, a threat or harm to the public interest, a violation or an attempt to conceal a violation of applicable laws and regulations or a breach of Candriam Code of Conduct.
EthicsPoint is a comprehensive and confidential reporting tool created by NAVEX which can be used 24 hours a day, 7 days a week. Whistleblowing reports are handled by Compliance Referents in a confidential manner and in accordance with the regulations in force.
The information you provide will be sent to Candriam by EthicsPoint on a totally confidential and anonymous basis if you should choose.
Why do we need a system like EthicsPoint?
- Our employees are our most important asset. By creating open channels of communication, we promote a positive work environment and maximize productivity.
- An effective reporting system augments our other efforts to foster a culture of integrity and ethical decision-making.
Reporting – General
What types of situations should I report?
Candriam's whistleblowing system targets breaches in legal, regulatory or prudential obligations, as well as Candriam's own internal compliance rules, with the potential to cause serious harm to Candriam.
Whenever a Whistleblower knows or reasonably suspects that one of the breaches covered by the whistleblowing system has occurred or is about to occur, then that person or body may use the whistleblowing system.
Examples of offences that fall in the scope of whistleblowing:- Public procurement;
- financial services, products and markets, and prevention of money laundering and terrorist financing;
- product safety and compliance;
- transport safety;
- protection of the environment;
- radiation protection and nuclear safety;
- food and feed safety, animal health and welfare;
- public health;
- consumer protection;
- protection of privacy and personal data, and security of network and information systems;
- classified facts, information or documents relating to national security;
- facts, information, or documents covered by medical secrecy;
In terms of the goal of defending the interests of the Group and its employees, the system is not intended to resolve problems associated with the performance of an employee's personal employment contract.
If I see a violation, shouldn't I just report it to my manager, security, or human resources and let them deal with it?
When you observe some behavior that you believe violates our code of conduct, we expect you to report it. Ideally, you should bring any concerns forward to your direct manager or other member of our management team. We recognize, however, 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. We would rather you report anonymously than keep the information to yourself.
Why should I report what I know? What’s in it for me?
We all have the right to work in a positive environment and 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. And, corporate misconduct can threaten the very existence of an entire company.
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. Also, offering positive input may help identify issues that can improve corporate culture and performance.
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 company who are charged with evaluating the report, based on the type of violation and location of the incident. At Candriam, whistleblowing reports are handled by Compliance Referents in a confidential manner and in accordance with the regulations in force.
Reporting Security & Confidentiality
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 our work environment (such as one located at an Internet café or at a friend’s house) through the EthicsPoint secure website.
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 seat next to Jan Smith…” or “In my 33 years…”.
What if I want to be identified with my report?
There is a section in the report to identify yourself, if you wish.
Tips & Best Practices
I am aware of some individuals acting unethically, but it doesn't affect me. Why should I bother reporting it?
Our company promotes ethical behavior. All unethical conduct, at any level, ultimately hurts the company 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.
I am not sure if what I have observed or heard is a violation of company policy, or involves unethical conduct, but it just does not look right to me. What should I do?
File a report. We'd rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked.
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. NAVEX makes these reports available only to specific individuals within the company 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 I remember something important about the incident after I file the report? Or what if the company has further questions for me concerning my report?
When you file a report at the EthicsPoint Web site or through the EthicsPoint Call Center, you receive a unique, randomized number called a “Report Key” and are asked to choose a password. You can return to the EthicsPoint system again either by Internet 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 now have entered into an “anonymous dialogue,” where situations are not only identified, but can also be resolved, no matter how complex.
Are these 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 anonymity.
What if I lose my Report Key or forget the Password I created?
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.
Can I still file a report if I don’t have access to the Internet?
You can file an EthicsPoint report from any computer that can access the Internet. You can file from home. Many public locations, including the public library, have Internet computers.