Scope of the whistleblowing system
The whistleblowing system enables CNIM Group employees as well as external or occasional employees and third parties (clients, suppliers and other CNIM Group partners), to raise an Alert, in accordance with the "Sapin II" law of 9 December 2016, relating to transparency, anti-corruption and economic modernization.
The use of this system is optional. It is an alternative that complements the usual communication channels, in particular internally: direct or indirect line manager, Human Resources Department, etc
Within the meaning of law no. 2016-1691 of 9 December 2016 known as the “Sapin 2” law, a Whistleblower must:
- Be a natural person;
- Be personally aware of the facts that he/she thinks should be revealed or reported;
- Be disinterested: he/she must not benefit, in particular financially, from making the report;
- Be acting in good faith: he/she must have reasonable grounds to believe that the facts reported are true.
The Alerts should refer to:
- A crime or an offense;
- A serious and manifest breach of an international commitment duly ratified or approved by France, an unilateral act of an international organization adopted on the basis of such a commitment;
- A serious and manifest breach of a law or regulation;
- A serious threat or prejudice to the public interest.
Accordingly, here are some examples of facts that could be the subject of an Alert:
- Insider trading;
- Psychological or sexual harassment;
- Human rights;
- Conflicts of interest;
- Anti-competitive practices;
- Environment ;
How may I raise an Alert ?
If you wish to raise an Alert, you may either fill in the Alert declaration form available here and to send it to the email address: email@example.com, or send a free email to the same address.
You may disclose your identity or choose to remain anonymous, in which case you must use an identity-preserving email address.
To issue an Alert, the Whistleblower may contact:
- The CNIM Group Ethics Commission via the e-mail address firstname.lastname@example.org
- Or a direct or indirect superior, the Human Resources Manager to whom you report, or your employer, who shall forward it without delay to the Ethics Commission at the same e-mail address.
The Group Ethics Commission is composed of the Group Human Resources Director, the Group General Counsel and the Group Data Protection Officer.
Will my Alert remain confidential?
In accordance with the regulations in force, all means are put in place to ensure strict confidentiality:
- Of the identity of the Whistleblower,
- Of the identity of the persons concerned by the Alert,
- Of the facts subject to the report and, more generally, any information communicated in connection with the Alert.
Protection of the Whistleblower
Subject to compliance with the conditions described in the Group internal procedure available here, the Whistleblower benefits from a legal protection, guaranteed by law.