"The Vicat Group grants great importance on complying with the laws and ethical principles governing its activities. Vicat has implemented a group-wide alert platform to report any conduct or situation that goes against the Group's internal rules or applicable laws and regulations."
Guy SIDOS, VICAT Group Chief Executive Officer
Who can report an issue via the Alert Platform ?
The Vicat Alert Platform is intended to receive reports regarding one of the following conducts or situations, transmitted by an individual acting in good faith: internal, external, or occasional employees of the Group (temporary workers or contractors), or third parties (such as a member of staff from a client or supplier of the Group).
It should be noted that if the whistleblower is an employee of the Group, they may also, depending on their preference and the circumstances, choose to report the issue to their direct supervisor or the designated contact for the concerned function, according to the conditions set out by the Group’s internal procedures.
How to report an issue via the Alert Platform ?
The Alert Platform is available under the Ethics section of the Group’s website. It allows reports to be made 24 hours a day, 7 days a week, via a form available in both French and English.
Here you can report :
What types of situations are eligible for reporting ?
These may include any conduct or situations contrary to the Ethics Charter or the Code of Conduct, as well as any other violations of laws and regulations, particularly in the following areas:
- Violation of a charter or a group code of conduct ;
- Corruption, fraud, competition law violations, money laundering ;
- Accounting, financial, or banking issues ;
- Public health protection ;
- Environmental protection ;
- Protection of privacy, personal data, and information system security.
How does it work ?
When the whistleblower submits a report via the Alert Platform, they are asked to fill out an electronic form, which includes indicating the country where the events related to the report occurred, the nature of the report, and their identity (if they agree to be identified and contacted).
Is it possible to submit an anonymous report ?
The Alert Platform allows for the submission of an anonymous report.
Who is responsible for analyzing the report ?
The admissibility of the report submitted via the Alert Platform will be reviewed by the Group Compliance department within a maximum of 7 calendar days from receipt.
If the report is deemed inadmissible, the non-anonymous whistleblower will be informed of the reasons why the report was not deemed admissible, and the report will be immediately destroyed.
If the report is deemed admissible, the non-anonymous whistleblower will be informed of the follow-up actions taken as part of the alert handling process.
What protection does the whistleblower receive ?
The whistleblower benefits from protections as outlined in the Group's professional alert management procedure.
Vicat also commits not to sanction, dismiss, or discriminate against any employee for a report made in good faith concerning facts within the scope of the internal alert system.
What confidentiality measures apply ?
Vicat ensures the confidentiality of the identity of the whistleblower, the person(s) implicated, and the information gathered by anyone responsible for receiving or handling the reports.
What personal data protection measures apply ?
Personal data is collected and processed by Vicat and the legal entity of the Vicat Group in the country where the events occurred, both acting jointly as data controllers in order to gather and process alerts aimed at reporting a breach of a specific rule, conduct necessary checks, determine the follow-up to the report, ensure the protection of the persons involved, and exercise or defend rights in court.
The legal basis for this processing is Vicat's obligation to comply with a legal requirement to implement a professional alert system.
The data recorded in the report is retained for the time necessary to process it and to protect the whistleblower, the persons targeted by the report, and any third parties mentioned, taking into account the potential length of further investigations. The data is only accessible to those authorized to handle it based on their duties.
The whistleblower has the right to access, correct, and delete their data, as well as the right to object to its processing and request limitations on its use.
When submitting a report, the whistleblower is provided with a detailed notice regarding the use of personal data.
The whistleblower may also contact the Group's Data Protection Officer by sending an email to the following address: dpo@vicat.fr. If, after contacting the DPO, the whistleblower feels their rights are not being respected, they may submit a complaint to the CNIL (French Data Protection Authority).
Procedure Whistleblowers