PAS Global Compliance Hotline
Frequently Asked Questions

The PAS Global Compliance Hotline is one of many channels for employees to speak up. Depending on the country where you are based, you can ask questions, seek help, and/or report potential violations of laws, regulations, Code of Ethics & Compliance, or company policies.

PAS has partnered with NAVEX to provide the PAS Global Compliance Hotline. The NAVEX System is a comprehensive reporting tool that provides you with a way to report by either phone or internet.

We cannot improve or correct problems, if we don't know they exist. When you first notice that something looks wrong, feels wrong, or sounds wrong, you must apply our company's core values and quickly report it. The PAS Global Compliance Hotline is one of many channels that employees or impacted stakeholders can use to make a report.

Yes, the PAS Global Compliance Hotline uses the NAVEX system to provide you with a way to file a report either by phone or on the Internet.

You should report any potential violation of law, regulations, Code of Ethics & Compliance, or company policy – though this may depend on the country where you are based.

Once you have chosen your region and country, you will be given a list of matters that can be reported.

If your concern pertains to a matter that under local law, may not be accepted by PAS through the Hotline, you will need to use any of the other reporting channels made available to you, such as your supervisor or local management or a representative of the Human Resources or Legal Department.

Some EU/EEA entities may also have local Hotlines, you will find more information on your Company’s Intranet.

PAS is committed to secure that also our suppliers and vendors comply with applicable law, regulations and social standards, including (i) to take due consideration of (a) the environment, (b) human rights and (c) health and safety of their personnel and of their suppliers’ personnel and (ii) to maintain the confidentiality of important information.

We require our suppliers to comply with Supply Chain CSR Promotion Guidelines. This includes an obligation for suppliers to make their employees aware of the possibility of reporting possible violations to the PAS Global Compliance Hotline.

If you have information that one of PAS’s business partners (including any suppliers or vendors in our supply chain) is not complying with applicable law, the Supply Chain CSR Promotion Guidelines or other standards, you can submit a complaint via the Global Compliance Hotline. You can also make a report to the relevant business partner directly.

When you first notice that something looks wrong, feels wrong, or sounds wrong, you must apply our company's core values and quickly report it. You have many official channels for speaking up. You can go to your manager; the next higher manager; the HR Department; the Legal Department. When you are not comfortable reporting an issue through these other channels, you also have the PAS Global Compliance Hotline.

We cannot improve or correct problems, if we don't know they exist. 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 PAS and our people.

For matters covered by the EU Whistleblowing Directive and national implementation laws, Reporters also have the possibility to make external reports to appointed local authorities. You can find a list of the competent authorities who can receive whistleblowing reports here.

Yes, all PAS companies have to follow internal rules of procedure as described here. All reports will be handled in line with this, as well as respecting all applicable laws.

Reports on the PAS Global Compliance Hotline are entered directly to a NAVEX secure server to prevent any possible breach in security. NAVEX makes these reports available only to specific individuals within PAS who are charged with evaluating the report, based on the type of violation and location of the incident.

Once the report has been examined, it may be followed up directly or forwarded to another responsible department for further investigation. Each of these report recipients, as well as any other employee or person subsequently tasked with following up your report, are impartial, subject to specific confidentiality obligations and have the necessary training to professionally and confidentially handle reports. Employees who may have a conflict of interest in the report or follow-up shall be excluded from follow-up of reports.

External advisors may be brought in to assist with the follow-up as relevant.

The company may contact you with follow-up questions or to discuss your report.

PAS does not tolerate retaliation of any kind. Anybody who makes a report in good faith, i.e. in the belief that the facts reported are correct even if later they turn out not to be true, will be fully protected against retaliation.

Where you have disclosed your identity in the report, we will only disclose this on a strict need to know basis and as permitted by law.

In some regions, PAS may have a legal obligation to notify any person who is the subject of a report to EARS, except where notice needs to be delayed to ensure the integrity of the investigation and preservation of relevant information. More generally, PAS will follow up reports in an impartial way and will, where necessary, also hear the employees implicated by a complaint or report.

All reports are taken seriously and will be assessed to see if there is sufficient information to follow-up the matter. In some cases, it may not be possible to follow-up the report without additional information. If such additional information is not received from the Reporter, we may have no choice but to abandon the investigation, in particular if we cannot specify the subject of an investigation and where it is too difficult to investigate a report. The Reporter will be informed should this be the case.

The individuals tasked with following up the reports, may conduct additional fact-finding through reviewing relevant documents, speaking with witnesses and affected parties and, if necessary, analysing data or documents (whether electronic or physical data). Any fact-finding shall be conducted in an impartial and un-biased manner, in full compliance with applicable law and internal procedures and respecting any rights of employee representatives or work councils.

Following the fact-finding, the results will be summarised in a report, which also may include recommendations for further follow-up, consideration of disciplinary sanctions or remedial measures. The reports will be shared with the necessary stakeholders in PAS.

The identity of the Reporter will be protected at all stages of handling a Report and any follow-up.

Yes, you will receive an initial confirmation that your complaint has been received. In some cases we may also contact you with follow-up questions or to discuss your report.

The PAS Global Compliance Hotline uses the NAVEX system. The NAVEX system does not generate or maintain any internal connection logs with IP addresses; no information linking your PC to the NAVEX system is available. In fact, NAVEX is contractually committed not to pursue a reporter's identity.

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, the library, at a friend's house, etc.) through the PAS Global Compliance Hotline NAVEX secure website.

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. Plus, NAVEX is contractually committed not to pursue a reporter's identity.

Every reasonable precaution, consistent with the needs of conducting a thorough and fair investigation, is taken to keep your identity confidential.

In addition, it is possible to report anonymously through the PAS Global Compliance Hotline except where legally restricted from doing so. The PAS Global Compliance Hotline uses the NAVEX system which is designed to protect you. In fact, NAVEX is contractually committed not to pursue a reporter's identity. To further ensure your anonymity, you—as a reporting party—need to be careful not reveal any identifying details as part of your report. For example, "from my cube next to Jan Smith…" or "in my 33 years…"

Finally, PAS supports all employees in raising issues or concerns in good faith and is committed to maintaining a retaliation-free workplace. Anyone who violates that trust and retaliates will face disciplinary action.

There is a section in the report where you may identify yourself, if you wish. Providing this information may help us thoroughly investigate the report.

When you first notice that something looks wrong, feels wrong, or sounds wrong, you must apply our Company's core values and quickly report it. One only has to consider what happened in recent corporate scandals to see the disastrous effects a seemingly harmless lapse in ethics can have on an otherwise healthy company. If you know of any incidents of misconduct or ethical violations, quickly report it.

You should report this in good faith through one of the channels available to you. We would rather you report a situation that turns out to be harmless than let possibly unethical behavior go uninvestigated.

The PAS Global Compliance Hotline uses the NAVEX system. This system and report distribution protocols are designed so that the implicated parties are not notified about or granted access to reports in which they have been named.

PAS has a strict no-retaliation policy and will protect your identity, see also above.

When you file a report with the PAS Global Compliance Hotline, either using the NAVEX System's Internet or phone system, you are given a unique report key and are asked to select a password. With this report key and password, you can return to the Hotline again, either by Internet or phone, and access the original report. At that point, you can add more details.

The PAS Global Compliance Hotline uses the NAVEX system which provides functionality to enable PAS representatives to post questions to you, even if you report anonymously. When you receive your report key, you will be provided with the amount of time we expect for the report to be processed. When that time has passed, we strongly suggest you use the report key and password to return to the Hotline either by internet or phone to see if any questions have been posted. If we need additional information and receive no replies to our questions, we may have to abandon the investigation.

If the telephone number listed is not functioning, please make your report online through this web site. Please indicate in the report that the telephone number did not work.

If there is no service for your location, please make your report online through this web site. Please indicate in the report that dialing instructions were not available for the country you are located in.