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.
This system complements the usual communication means and the usual remedies open to all Group employees: direct or indirect line manager, Human Resources Department, management representatives, etc.
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, the scope of the whistleblowing process covers the following areas in particular:
- Insider trading;
- Psychological or sexual harassment;
- Human rights;
- Conflicts of interest;
- Anti-competitive practices;
On the other hand, pursuant to Article 6 of the Sapin II law, the following are excluded from the scope of the procedure: acts, information or documents, regardless of their form or medium, covered by:
- National defense
- Medical confidentiality
- Attorney-client privilege.
Under which conditions and how may I raise an Alert ?
To raise an Alert, you must have personally witnessed the alleged misconduct and act in good faith.
The whistleblowing system is accessible 7 days a week, 24 hours a day.
If you wish to raise an Alert, you are required to fill in the Alert declaration form, available in English and French versions, and to send this form to the following email address: email@example.com
Alerts raised anonymously will not be processed under the whistleblowing process except in exceptionally serious cases or when the acts mentioned are accompanied by sufficiently detailed factual information.
What should my Alert contain?
You are encouraged to provide detailed factual and objective information on the facts that motivate your Alert. An Alert can be processed if it contains enough information and if it is reasonably possible to obtain additional information.
Who is my Alert addressed to and how is it processed?
The Alerts are sent to the Referent Ethics Manager, CNIM Group third party.
You receive an acknowledgment of receipt of your Alert within 72 hours, which does not prejudge its admissibility.
The Referent Ethics Manager examines the Alert to determine whether:
- It is in the scope of the whistleblowing system;
- It is sufficiently detailed to be processed.
The deadline for examining the admissibility of the Alert is 20 working days maximum following the acknowledgment of receipt of the Alert.
Any Alert that clearly falls outside the scope of the whistleblowing system, is considered in no way serious, was raised in bad faith, constitutes an unfair or false accusation, or relates to acts that cannot be verified, is immediately destroyed. The whistle-blower is then informed.
If the Alert is admissible, it is then managed by the Ethics Compliance Committee, Internal Committee responsible for the instruction of the admissible Alerts. For this purpose, the members of the Ethics Committee are bound by a reinforced obligation of confidentiality.
Will my Alert remain confidential?
The Alert is in all cases handled confidentially: your identity, the facts reported and the identity of the person (s) referred to in the Alert are confidential.
No information concerning the identity of the whistle-blower will be disclosed unless the Group is required to do it by law.
The Group undertakes to take all necessary measures to protect the identity of the whistle-blowers.