Whistleblowing Policy - Speaking Up Procedure
In order to continuously strengthen its ethical commitment and notably in accordance with the Directive (EU) 2019/1937 of 23 October 2019 on the protection of persons who report breaches of Union law, the present Whistleblowing Policy provides with a secure and confidential channel to allow you to speak up should you identify a violation of laws, our EVS Code of conduct or any internal policies/procedure. EVS is committed in this context to ensuring that everyone feels free to speak up without fear of retaliation and to investigating any potential instances of misconduct.
Who can issue a report?
- Any team member of EVS and its affiliated companies, including temporary workers, trainees and interns
- All stakeholders of EVS, external and occasional, including customers, subcontractors, suppliers and partners.
The Whistleblower must act in good faith, without malicious intent and without expectation of compensation. Any abuse of this reporting channel will result in disciplinary sanctions and/or judicial proceedings.
When should a report be issued?
The Whisleblower is invited to use the reporting channel below if he/she identifies a violation of laws, our EVS Code of conduct or any internal policies/procedure in particular , but not exclusively to the following areas:
- Human rights
- Data privacy
- International sanctions
- Health & Security
- Any crimes or offences
What is the process for submitting a whistleblower report?
If the Whistleblower is an EVS Teammember, he/she is first encouraged to report his/her concerns to his/her manager or HR department.
If this is not the case, not possible, or if no effective action has been taken following an initial internal report, then a report can be made according to the procedure detailed below.
- The Whistleblower can make a report, anonymously or not, by sending an email to the following address: email@example.com. The whistleblowing reporting channel is open to anyone, at any time, 24 hours a day, and is available in English and French.
- The report is then processed by specific and competent staff members who are subject to confidentiality obligations.
- A report is drawn up on the basis of the information provided by the Whistleblower. The Whistleblower receives an acknowledgement of receipt within 7 days of reporting.
- The facts reported are then examined and an investigation may be launched if necessary. The Whistleblower is kept informed of the outcome of the report within three months.
- The investigation makes it possible to establish the facts, obtain evidence and ensure the reality and materiality of the facts reported.
- Depending on the conclusions of the investigation, disciplinary proceedings or legal action may be taken.
What protection does the whistleblower have?
If applicable, EVS shall protect those who speak up and raise concerns appropriately and in good faith from any form of retaliation, potentially including, where appropriate, support measures such as information, protection assistance or legal support.
Confidentiality and data protection
EVS undertakes to treat all reports in the strictest confidentiality. Information such as the identity of the Whistleblower, the identity of the person(s) implicated and the suspicions or facts reported is kept strictly confidential. The identity of the Whistleblower may only be revealed with his or her consent or if very specific circumstances require to do so.
Personal data are also processed in strict compliance with the General Data Protection Regulation (GDPR), and in particular during the collection, communication and conservation of data. The Whistleblower has a right of access, rectification, object and deletion of this data through firstname.lastname@example.org.