Speak Up, our ethical contact line

Trust, mutual respect, and integrity are core values for us.

In accordance with our commitments and French law (including Law No. 2022-401 which aims to improve the protection of whistleblowers), we provide you with a confidential and secure reporting process.

You can use this system to inform us of any serious misconduct of which you are personally aware and that concerns our company. Your vigilance is essential in helping us prevent and address risks.

The law protects a wide range of individuals. This reporting mechanism is not only to our employees but also to our broader ecosystem. You may file a concerns if you are:

• A company employee: whether you are currently employed (regardless of contract type: permanent, fixed-term, apprenticeship, internship, etc.) or a former employee.

• A job applicant at our company, if the information was obtained during the recruitment process or the issues were experienced during the recruitment process.

• A shareholder, partner, member of the administration, management.

• An external or temporary employee: client, partner, service provider, supplier, subcontractor, or any member of their staff.

In summary, any individual who, in a professional context with our company, has obtained information relating to the matters described below.

You may be the whistleblower yourself or act to personally ensure the protection of a whistleblower.

Reports must be made in good faith and must concern information that you have obtained personally. 

They must not relate to facts that are already fully known to the public.

You may use this system to report a crime, an offense, a threat, or harm to the public interest, or a violation (or an attempt to conceal a violation) of the law, regulations, or a contract. You may use this system to report specific facts even if you are unsure whether they qualify as admissible or inadmissible, essentially to resolve any doubts. 

The following areas are covered by our reporting system:

A. Discrimination, Harassment, and Conduct That Undermines Dignity

Any conduct or remarks that are:

• Discriminatory on the basis of origin, sex, age, disability, sexual orientation, gender identity, political opinions, union activities, or religious beliefs.

• Constitutes psychological or sexual harassment.

• Is sexist, racist, or undermines the dignity and respect due to individuals.

B. Fraud, corruption, and breaches of integrity

• Acts of active or passive corruption, or influence peddling.

• Situations involving conflicts of interest.

• Acts of social fraud or fiscal fraud.

• Any action intended to evade financial or accounting laws and regulations.

C. Security, Confidentiality, and Data Protection Incidents

• IT security incident: unauthorized access to our systems, ransomware attack, etc.

• Breach of confidentiality: unauthorized disclosure of strategic, commercial, or technical information.

• Personal data incident: data breach (loss, theft, alteration, disclosure) as defined by the GDPR, or failure to comply with data protection principles.

D. Health, personal safety, and environmental protection

• Acts representing a serious risk to the health and safety of individuals (employees or third parties).

• Practices constituting a serious risk to the environment

E. Other serious violations of laws or regulations 

• This category covers any other serious act not listed above that constitutes a clear violation of a law, regulation, or European or international commitment applicable in France, or of a contract.

The law provides you with significant protection, particularly when you act in good faith. The Defender of Rights, a French institution, can assist you, particularly through the informational and human resources at its disposal: 

https://www.defenseurdesdroits.fr/guide-du-lanceur-dalerte-314

Our procedure includes a process for clearing up any doubts. Our procedure protects your anonymity, as this is both in our best interest and a strict legal requirement.

Other parties may also assist you, depending on your choice, and they too must protect your anonymity.  

• as an employee of our company or another organization, another employee, a representative on the Social and Economic Committee (CSE), a member of the management team

• in general, a lawyer

• in general, non-governmental organizations with expertise in a particular area

• in general, various specialized public authorities (CNIL, ANSSI, the Defender of Rights, the French Anti-Corruption Agency) 

This secure form allows you to initiate contact. 

After explaining the facts, dates, and whether your account is based on firsthand or secondhand information, you can indicate how you would like to be contacted (email or phone) or, alternatively, specify that you do not wish to be contacted. 

Free-text fields:  

• Your report: facts, dates, and nature of your testimony

• How would you like to be contacted? (email or phone)

Instead of your usual email address, or that of a third party authorized by you, you can use this form with a temporary email address created by you and dedicated to our correspondence.

Reports will be reviewed by a committee composed of the Company’s President, the Director of Human Resources and Customer Satisfaction, and a non-employee member of the Board of Directors selected for their expertise in law and ethics.

This committee is not an independent body, but each member of our committee is required to protect your anonymity. 

If you have provided contact details, we are required to inform you of the action we have taken in response to your report. 

First, within seven days, you will receive an initial acknowledgment of receipt of your report. We will confirm, in particular, that we intend to protect your anonymity and the timeframe required by law or by us.

Regarding the substance of the matter, and within three months (or six months if we have referred the matter to a dedicated administrative authority due to the nature of the issue), we will provide you with feedback on the findings of our internal investigation.

If applicable, we will inform you that the investigation is still ongoing, has been closed due to insufficient evidence, or is deemed outside the scope of the system, and we will then direct you to the appropriate contacts.

This report will always be recorded in our dedicated systems according to the topics raised.

Of course, while the level of detail may vary due to the need to protect your rights and those of third parties, we will also inform you of the measures being considered or taken.

If you have reasons to be dissatisfied, if you wish to seek redress beyond what we have already done, or if you continue to observe concerning issues, you retain significant freedom of action, provided you comply with the laws governing the matter in question.

You may consult a lawyer, a third-party institution, a judicial or administrative authority, or even submit another report via our hotline. 

This system is not primarily intended to handle customer complaints or disagreements regarding your personal situation (job applications, evaluations, assignments, etc.) when these matters do not involve a serious violation and can instead be addressed through the usual channels (customer service, human resources, employee representatives).

After obtaining your consent, and to the extent possible given the reasonable size of our company, we will also address these other matters based on your request and subsequently through the more standard channels.