Ethics Alert System
Why? For Who?
The Group is strengthening its commitments to ethics and the fight against corruption by providing its employees and all stakeholders (subcontractors, clients, suppliers, etc.) with a whistle-blower mechanism.
This mechanism allows any person who is a victim or a witness of the following acts, to report them to an independent entity responsible for relaying the information to our Ethics Alert Committee, while protecting your identity and ensuring your anonymity:
a crime or offense
any serious violation of a law, regulation, or international commitment regularly ratified or approved by France
all obligations defined by European regulations and the Monetary and Financial Code (CMF) or the General Regulation of the Financial Markets Authority (AMF)
and more specifically, behaviours or situation contrary to the company’s Anti-Corruption Charter, concerning acts of corruption or influence peddling
Any violation (or breaches) reported through our ethics alert line will be investigated by the Group’s Ethics Alert Committee.
Anonymity and Confidentiality
The whistle-blower can choose not to disclose their identity: His/her anonymity will be preserved!
Devoteam Group, has chosen to outsource the management of its ethics alert line to maximize its effectiveness and ensure complete confidentiality of the actions taken by the whistle-blower.
Our external service provider acts independently of the Group and gives you the opportunity to make a report completely anonymously and confidentially. Then, they transmit the anonymous information to the Group’s Ethics Alert Committee.
No retaliatory measure can be taken against the whistle-blower, whether they are an employee of the Group or a stakeholder. However, any misuse of the ethics hotline could lead to legal actions (or prosecution) or sanctions.
Data protection policy
Devoteam’s Group attaches the highest importance to data protection and confidentiality and complies with the provisions of the European Regulation “on the protection of individuals with regard to the processing of personal data and on the free movement of such data” (EU-GDPR) as well as applicable national regulations on personal data protection.
Before submitting a report, we kindly ask you to carefully read the information on data protection.
Purpose of the Whistle-Blower Mechanism
The Group’s Ethic Alert System, through the EthicsPoint platform, is intended to securely and confidentially collect, process, and manage reports related to breaches of the ethical and compliance codes of conduct of Devoteam’s Group or its subsidiaries’ to alerts relating to the fields covered by Law No.2016-1691 of December 9, 2016, on transparency, fight against corruption and the modernization of the economy (known as Sapin II Law) and Law No.2017-399 of March 27, 2017, on the duty of vigilance of parent companies and ordering companies.
Responsibility of the Mechanism
The Corporate Audit and Internal Control Department of Devoteam’s Group is responsible for the Ethics Alert Mechanism. They can be contacted at the following address:
Corporate Audit and Internal Control Department
73 Rue Anatole France
The platform is managed by a global specialist company in outsourced ethics hotlines, NAVEX GLOBAL UK LIMITED, located at Vantage West, 4th Floor, Great West Road, Brentford, TW8 9AG, United Kingdom.
Personal data collected
By submitting report through the EthicsPoint platform, some personal data and information will be collected:
Your name if you disclose your identity
Your status as an employee of Devoteam SA or of the relevant subsidiary, your status as an external collaborator, as an occasional collaborator related to Devoteam SA, or the subsidiary of the group concerned
Your relationship with a third party, if you disclose it
The actions you would like to bring to the attention of the group’s management
The names and other personal data of the individual(s) mentioned in your alert report.
Confidential Processing of Reports
Reports are always treated with the utmost confidentiality. Members of the Ethics Alert Committee analyse the admissibility of the report, communicate with the whistle-blower, and take the necessary actions to investigate the case until its closure. Anyone accessing the data is required its strict confidentiality.
Information of the Individual(s) concerned by the report
The person mentioned in an alert report is informed of the personal data concerning him/her in the platform. He or She does not have any information enabling to identify the whistle-blower.
If precautionary measures are necessary, especially to prevent the destruction of evidence or for the needs of the investigation, informing this person may occur after the adoption of these measures, in accordance with applicable legal provisions.
Rights of the Individuals Concerned
Under the applicable data protection regulations, the whistle-blower, and the individual(s) concerned by the report have the right to information, access, rectification, erasure, and objection to the processing of their personal data.
When the right to erasure is invoked, the Ethics Alert Committee promptly examines to what extent there are no longer legitimate and compelling grounds for the processing that outweigh the interests, rights, and freedoms of the data subject, or for the establishment, exercise, or defence of legal claims. In addition, the whistle-blower and the individual(s) mentioned in the report have the right to lodge a complaint with a supervisory authority.
Retention period for personal data
Personal data shall be kept for the period necessary to verify and investigate the alert or as provided for, by the applicable law. Once the alert is processed, the personal data shall be destroyed within two months of its closure. The anonymized alert is archived in accordance with applicable laws.