The Groupe ADP’s Ethics and Compliance commitment

Ethics and Compliance, defined as adherence to laws and regulations, are key drivers of trust for all the Group’s stakeholders. The whistleblowing system is one of the core pillars of the ethics and compliance program. It provides employees with an additional channel to raise concerns and reflects Groupe ADP’s commitment to continuous improvement.

A concern / to make a report / to file a report Access an existing report

Important

Accessible 24/7, the alert system is based on 4 commitments:

The protection of the whistleblower and of the facilitators acting in good faith and without any direct financial consideration
The presumption of innocence of the individuals targeted by the alert
The proper conduct of the parties involved in collecting and processing the alert
The respect for the confidentiality of the facts and the identity of the individuals involved, especially the whistelblower.

The whistleblowing system allows people to ask questions via a secure platform about sensitive situations or to report facts that go against the Group’s values or applicable rules (laws and regulations, code of conduct), whether anonymously or not.

When you submit your alert, you will receive a unique code that you must keep in order to access the various messages on the platform at a later date.

FAQ

Who can submit an alert ?

An employee or former employee of a company of Groupe ADP
An applicant for a job in a company of Groupe ADP
A shareholder, partner or holder of voting rights in the general meeting of a company of Groupe ADP
A trainee, employee on secondment, temporary employee or any other status of external and/or occasional employee in a company of Groupe ADP
A supplier, subcontractor, service provider, an association or any other external partner of a company of Groupe ADP
A customer or a user of the facilities managed of a company of Groupe ADP
A member of a local community or any other stakeholder potentially impacted by the activities of a company of Groupe ADP
A facilitator (natural or legal person who has helped to facilitate the disclosure or reporting by a whistleblower)

What can be reported ?

A serious and manifest breach of the ADP Group’s Code of Conduct or associated Ethics and Compliance procedures (e.g. corruption, influence peddling, conflict of interest, breach of free competition, breach of the gifts and invitations policy, breach of the protection of information and personal data protection).
A crime a criminal offence (e.g. aggravated theft, rape, assault) or offence (e.g. tax fraud, misuse of company assets, sexual or psychological harassment, discrimination of any kind).
A violation or an attempt to conceal a violation of the law, a regulation (e.g. a decree, an order), an international commitment duly ratified or approved by France, European Union law, or a unilateral act of an international organisation.
A situation that may present a threat or harm to the general interest (e.g. actions likely to present a danger or harm to the safety of the population in the area of health or the environment, serious infringements of human rights and fundamental freedoms).
Retaliatory actions linked to having reported a concern or participated in its handling.

Is my report admissible ?

Does my status falls within the categories defined in ‘Who can report’?
The facts I am reporting fall within the scope of the whistleblowing system (see ‘What facts can be reported’?)
The facts I am reporting are sufficiently precise, detailed and substantiated to be processed (see ‘What does an accurate description of the facts mean’?).
I will receive a reply on the admissibility of my report within a maximum of 3 months following the sending of the acknowledgement of receipt.
If my report is not admissible, it will be closed
If my alert is admissible, the processing phase will begin
The analysis of the admissibility of my report may require clarification. I must therefore remain attentive to notifications from the alert platform in order to answer any questions via its secure messaging system.

What does an accurate description of the facts mean ?

Objective facts that are materially verifiable and relevant to the breaches in question
The place and date, or estimated timeframe, of the reported events
The circumstances in which the reporter became aware of was informed of these events
The identity and functions of any alleged perpetrators and victims
The existence of witnesses and, if applicable, their identity and functions
The existence of legal or similar proceedings (mediation, arbitration, etc.) that are imminent or ongoing.
Wherever possible, supporting documents should be provided

What are the main stages in handling an admissible report ?

I have been informed of the admissibility of the report and of the ongoing process.
A Processing Committee has been set up to validate the investigation strategy and ensure compliance with the fundamental principles of the investigation (confidentiality, objectivity, impartiality, incriminating and exonerating evidence)
At the end of the investigations, the Processing Committee validates :

- The anonymised investigation report

- The recommendations made

- Any feedback to the whistleblower and to the persons concerned by the recommendations

What happens once the alert is closed ?

At the end of the investigations and reporting process, and in order to ensure the ongoing protection of stakeholders beyond the investigation :

- All investigation documents are destroyed

- Only the following documents are archived in secure storage areas for a limited period of 12 years:

- Investigation process traceability documents (e.g. control sheets, etc.)

- The report and its appendices

- The recommendations made

Stakeholder protection may continue beyond the investigation to prevent any form of reprisal. You can continue to communicate via the alert platform if necessary.

How is confidentiality ensured ?

To ensure confidentiality at every stage of the alert and investigation :

- Each stakeholder signs a confidentiality undertaking

- All documents are anonymised and stored on a secure platform with restricted access

- Interviews are conducted in rooms that guarantee confidentiality

The main principles of internal investigations

A Processing Committee is set up to validate the investigation strategy and thus guarantee compliance with the fundamental principles of:

- Confidentiality (investigations are carried out by investigators who sign confidentiality agreements, as do all the parties involved in the investigations and the members of the Processing Committee)

- Impartiality : an investigation carried out with both the prosecution and the defense in mind

- Objectivity: there is no bias and there is a right to be presumed innocent

- Proportionality of the resources deployed to the subject facts and delicacy of the same.

Useful documentation

Codes of conduct

Whistleblowing system charter