Whistleblowing Policy

This policy aims at operating on a highly transparent basis. The company wants to be aware of significant wrongdoings and address them as soon as possible. All complaints or concerns regarding accounting, legal matters, fraud or non-compliance may be addressed through this Policy.

This policy does not aim at replacing communication of concerns, questions or issues by employees or third-parties to the hierarchy, supervisors, Ethics Champions or Human Resources. This is an additional communication channel that may be used to report significant matters.

Matters that May be Reported

Employees are encouraged to immediately report:

  • Intentional error, fraud, negligence in the preparation, review or audit of any of the Company’s Financial Statement or in the recording of the
  • Company’s Financial records
    Intentional noncompliance cases with the company policies or with the applicable laws
  • Any identified fraudulent activities (bank fraud, money laundering, fraudulent statements to management, fraudulent use of access rights…)
  • Violations of the Anti-Corruption Laws (FCPA, Loi “Sapin 2”, UK Bribery Act or similar laws) and violations of the Code of Ethics (for example, corruption, discrimination, harassment…)

Other topics or concerns must not be shared using this communication channel but addressing the point with supervisors or with Human Resources.

Third-Parties are encouraged to immediately report:

  • Intentional noncompliance cases with the applicable laws
  • Any identified fraudulent activities (bank fraud, money laundering, …)
  • Violations of the Anti-Corruption Laws (FCPA, Sapin2, UK Bribery Act or similar laws) and violations of the Code of Ethics
Raising Complaints

Complaints may be raised confidentially and, if desired, anonymously to the fullest extent legally permitted in your local jurisdiction:

  • Via email at Group Level using the email Ethicspoint@exclusive-group.com
  • Via Regular Mail to Exclusive France Holding – Group General Counsel – 20 quai du point du jour – 92 100 Boulogne-Billancourt- France

The anonymity of the person raising a non-anonymous complaint will be maintained to the fullest possible extent and as per the requirements of the law.

Complaints will be treated confidentially.

Raised complaints must include a clear description of the facts or concerns, the entity name and possibly provide information on the sources of information, consequences and impacts. Alerts that include non-verifiable facts, non-significant facts or that are out of scope of this policy will be deleted immediately.

Anonymous alerts will be treated only if the facts described are provided with enough detail.


Treatment of Complaints

Received complaints will be logged into a single report kept available by the recipient of the complaint. Date of the complaint, description, submitter if non- anonymous, status of investigation, conclusions will be reported on the report.

Risk & Compliance will ensure coordination of the treatment of the complaints and may report immediately the significant items to the Risk Committee. A quarterly reporting will be communicated to the Risk Committee with complaints received and updates on pending investigations. Access of reports to third parties will be at the discretion of the Risk Committee.

When appropriate, complaints may be transferred to the appropriate person or department to be treated unless the complaint involves this specific person or department. Complaints will be anonymized before being transferred internally. Confidentiality will be maintained to the fullest possible extent.

If some individuals are the subject of the complaint, they will be informed about the ongoing treatment of the alert once first investigations are initiated (in order to avoid that any proof or evidence disappear). This is to provide them with the right to oppose the treatment of the case for a legitimate reason (false accusation or scurrilous allegation for example).

Anonymous alerts will be marked as such in the communications made during the related investigation.

Prompt and appropriate corrective action (including disciplinary action up to termination of employment) shall be taken as determined by the Risk Committee and depending on the nature and gravity of the conduct or circumstances.

Reprisal, threats, retribution or retaliation in any way against any person who has in good faith made a complaint or reported a concern, or against any person who assists in any investigation or process with respect to such a complaint or concern, is prohibited. Employees who believe that they have been subjected to such reprisal, threats, retribution or retaliation may raise the case to the General Counsel.

On the contrary any bad faith complaints raised may lead to disciplinary actions against the submitter.

Communications and documents related to alerts that did not lead to any disciplinary or legal actions will be deleted or archived after being anonymized within two months after the case is closed. Cases leading to further disciplinary or legal actions will be archived as per legal requirements.

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