The procedure for collecting and processing reports concerning the companies listed above is available on the Alma Group website: www.alma-group.com for all persons and is available on KELIO for current employees.
The platform is permanently available in French and English.
This reporting platform enables the categories of people listed below to report any fact of an illicit nature or detrimental to the public interest, so that we can remedy the situation.
The persons who can issue an alert are :
- A candidate for employment when the information was obtained as part of the application process;
- A member or former member of the company's staff when the information has been obtained in the course of a professional or employment relationship;
- An occasional external collaborator;
- A shareholder, partner or holder of voting rights at a shareholders' meeting;
- A member of the administrative, management or supervisory body;
- A co-contractor of the company, a sub-contractor, or in the case of legal entities, members of the administrative, management or supervisory bodies of these co-contractors and sub-contractors, as well as members of their staff.
These alerts concern information relating to a crime or misdemeanor, a threat or harm to the general interest, a violation or attempted violation of an international commitment duly ratified or approved by France, a unilateral act of an international organization taken on the basis of such a commitment, European Union law, or a law or regulation.
Definition of a whistle-blower and description of the facts
A whistleblower is a natural person who reports or discloses, without financial consideration and in good faith, information concerning a crime, a misdemeanor, a threat or harm to the general interest, a violation or an attempt to conceal a violation of international or European Union law, law or regulation.
As such, the facts that are the subject of the alert must be presented in an objective and factual manner, making clear their presumed nature, and present a direct link with the subject of the alert.
Protecting whistle-blowers
Whistle-blowing is not always easy, which is why we have implemented a process designed to ensure strict confidentiality, impartial and diligent handling, protection against reprisals and compliance with national legislation.
Anonymity
As an exception, it will be possible to issue an alert anonymously, provided that: the seriousness of the facts is established; the factual elements are sufficiently detailed; and the handling of this alert is subject to special precautions, such as a prior examination of the appropriateness of its dissemination within the framework of the system.
As an exception, it will be possible to issue an alert anonymously, provided that: the seriousness of the facts is established; the factual elements are sufficiently detailed; and the handling of this alert is subject to special precautions, such as a prior examination of the appropriateness of its dissemination within the framework of the system.
Processing alerts
The person wishing to make an alert chooses the category to which his/her alert will be sent. Each alert will be directed to two referees to compensate for the absence of one of the referees. In addition, if one of the two main referees is directly or indirectly concerned by the alert, the sender of the alert may choose to send the alert to the “Other” category, made up of two internal referees not designated within the following predefined categories: Social, Ethical and Environmental. The names of the referees to whom the alert will be sent are specified on the alert completion page.
Depending on the subject and the entity to which the alert relates, internal referrers may be asked to call on one or more persons, in a limited number, with the necessary knowledge and skills to participate in the analysis of the facts reported and to help process the alert in question. Internal referrers will ensure that this is necessary to process the alert in question, and that there is no conflict of interest. The persons invited will be required to observe the necessary confidentiality and impartiality.
In order to assess the accuracy of the allegations, and depending on the nature of the breaches reported, the internal referents may conduct an investigation, or even commission an expert report.
Process
- Once a report has been registered on the platform, the people authorized to process reports on the platform will verify the facts reported, in complete confidentiality, in order to determine whether the report is admissible and to make an informed decision on the action to be taken.
- The author of the report will be kept informed of the processing of the alert via a confidential and, if necessary, anonymous online discussion forum. This space also enables clarification and exchange with case managers. Information concerning access to this area should be carefully stored in a secure location.
Processing times are as follows:
- 7 days to acknowledge receipt of the alert to the sender ;
- 3 months (from the above-mentioned acknowledgement of receipt) to inform the issuer of the alert of the measures envisaged or taken to assess the accuracy of the allegations and, where appropriate, to remedy the subject of the alert, as well as the reasons for these measures. This does not mean that the alert must be resolved within three months.
Data retention
If an alert is declared inadmissible as soon as it has been reported, the data relating to the alert is destroyed or anonymized without delay.
When the alert is not followed by disciplinary or legal proceedings, and when two months have elapsed from the completion of all verification operations, any data that might enable the author of the alert to be identified is destroyed or made anonymous.
When disciplinary proceedings or legal action are taken against the accused person or the author of an abusive alert, the data relating to this alert is kept until the end of the proceedings and the expiry of any appeal against the decision.
The author of the alert will be informed in writing, via the discussion area, of the closure of the file.
External whistle-blowing
whistle-blowers can also submit an external whistle-blowing report, either after having submitted an internal report, or directly, without having to provide any justification. The list of competent authorities in France is appended to Decree no. 2022-1284 of October 3, 2022 on procedures for collecting and processing whistleblower alerts and establishing the list of external authorities instituted by Law no. 2022-401 of March 21, 2022 aimed at improving the protection of whistleblowers. In Luxembourg, external whistleblowers can report to a competent authority listed in article 18 of the law of 16/05/2023 transposing Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report violations of Union law.
whistle-blowers can also submit an external whistle-blowing report, either after having submitted an internal report, or directly, without having to provide any justification. The list of competent authorities in France is appended to Decree no. 2022-1284 of October 3, 2022 on procedures for collecting and processing whistleblower alerts and establishing the list of external authorities instituted by Law no. 2022-401 of March 21, 2022 aimed at improving the protection of whistleblowers. In Luxembourg, external whistleblowers can report to a competent authority listed in article 18 of the law of 16/05/2023 transposing Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report violations of Union law.
---------What to do if you lose your login details for your personal space ----------------
You can create a new alert by explaining your situation and the alert you have already filed. The referrer will then be able to communicate with you through the newly created communication space.
You can create a new alert by explaining your situation and the alert you have already filed. The referrer will then be able to communicate with you through the newly created communication space.
This system is hosted by a service provider who has no access to the data, but guarantees its operation.
How our whistleblower system helps protect your privacy
- No identifying information is provided to the contacts.
- Your message will be stylometrically redacted to provide you with an even higher level of anonymity. We remove all punctuation and convert all words to lowercase."
- All information is end-to-end encrypted, so your sensitive information remains safe.
What you can do to protect yourself
- You are not on the corporate network (Internet/VPN).
- You should not use a device (smartphone, computer, etc) that is provided by your employer.
- You should not use the kinds of idioms or abbreviations that you frequently use in conversations or when writing emails.