Speak Up

We are open to any concern that you may have, but we aim specifically at breaches of our Code of Business Ethics, policies, laws, and regulations. Examples of misconduct that can be reported include, but are not limited to:

• situations breaching human rights, including harassment, child labor, etc.

• financial and accounting concerns and asset misappropriation.

• corruption or other criminal offences, including bribery, conflicts of interest, illegal gratuities, fraud, etc.

• breaches of competition rules. 

• situations which endanger the health or safety of individuals or cause damage to the environment.

• situations which result in a risk to the privacy of individuals.

If you want to report events presenting an immediate threat to life or property, please do not use the Speak Up platform, as reports submitted through them may not receive an immediate response. If you require emergency assistance, please contact your local authorities.

Please provide as much relevant information as possible. The more details of the case you can give, the more effective the investigation can be. 

The information and data to be provided:

- should be detailed, objective and directly related to the subject matter of the report. You do not have to wait to have all the facts to raise your concern, as this might not always be possible. Share the facts that you have, so your concern is assessed as soon as possible.

- will enable the investigator to make a proper assessment and allow for understanding of what has happened and, if needed, request more information.

include:

• Your contact details, if you are not reporting anonymously.
• A detailed description of the situation of concern as well as antecedents and/or examples
• Names and positions of people potentially involved (including witnesses), dates, places
• When and how (directly or indirectly) you became aware of the matter
• Whether steps have already been taken to remedy the situation.
• Whether you have already shared your concern with others. In particular, please indicate whether, to the best of your knowledge, your concern is already being assessed internationally or externally (e.g. in a judicial or similar proceeding).
• Any supporting facts and documents related to the concern. 

Concerns shared through the platform are received by the Business Ethics team and shared with appropriate and independent internal partners. When you file a report through the Speak Up website or call center, you will receive a unique username and select a password. You can then return to the platform either online or by phone (we encourage you to download the app) to access your original report and add more details or updates.

The receiver will acknowledge receipt of your concern and will manage your case directly or revert to another person/team who will be able to handle it in better condition. The receipt of the report must be confirmed to the reporter within seven days. Furthermore,  he or she must be informed of any action taken within three months, as well as the status of the internal investigation and its outcome. You will receive a tracking number to check the status and answer follow-up questions.

The person handling the case will decide on the next steps. This could be opening an investigation, asking for more information, not taking further action for lack of information or facts to proceed, or because the report does not represent a real or potential breach of policies, laws, and/or regulations. 

You will periodically receive updates on the investigation until the closure of the case. In all cases, the investigation will be registered, and the records will be kept confidential.