5. 5.1.3 Whistleblowing In accordance with the provisions of France’s “Sapin II” law (2016) and “Corporate Duty of Care” law (2017), GEODIS has set up a whistleblowing system, enabling employees and temporary or external workers, as well as suppliers, partners and third parties, to report incidents from France or abroad, anywhere in the world. Subject to the conditions of admissibility stipulated by the law and stated in the internal whistleblowing policy, the whistleblowing system makes it possible for the Group to receive information concerning any suspected or proven breach of the law, a regulation or the Code of Ethics, and any risk of serious infringement of human rights and fundamental freedoms, the health and safety of individuals, or the environment. The system works alongside other reporting channels available within the Group, especially approaching line managers or the Human Resources Department. Whistleblowing policy GEODIS’s whistleblowing mechanism is supported by a dedicated internal policy, available in ten languages, which guarantees the protection of whistleblowers in accordance with legal and regulatory provisions, particularly regarding the prevention of any form of retaliation. Digital platform Users (employees and third parties) have the choice of accessing the system via a dedicated BKMS® System digital platform or via dedicated internal e-mail addresses at central or local level. The availability of the BKMS® System platform makes the system more accessible and offers the best guarantees in terms of data confidentiality and security. Users can submit their alerts in written form directly to the platform, or by phone. They can remain anonymous in countries where this is permitted by local law. The BKMS® System platform also facilitates and optimizes internal alert processing. To encourage people to use the system, the platform launch was the subject of an extensive internal communications campaign, both electronically and through posters (to reach employees with no access to a computer workstation). Statistics on alerts received in 2023 The Governance, Risks and Compliance Department organizes the collection and processing of alerts received at central level. It monitors key data relating to alerts received and processed, both centrally and locally, and relays them to the Risk Committee. In 2023, 322 ethical alerts were received at Head Office and in the lines of business and regions via the alert system (platforms and dedicated e-mail addresses), Compliance officers and the Human Resources Department. Of these 322 alerts, 186 were found to be admissible, representing a rate of 58%, reflecting a good understanding of the system by users thanks to the communications and awareness-raising campaigns. 173 (93%) of the 186 admissible alerts were processed and concluded during the year, demonstrating the efficiency of the teams assigned to handling alerts. 5.1.4 Specific programs GEODIS has set up specific programs to manage the risks of breaches of applicable rules on anti-corruption, competition law, personal data protection, customs and export control, as required by applicable laws and regulations, as well as by the Group’s Code of Ethics. 5.1.4.1 Anti-corruption program GEODIS has introduced a compliance program to combat corruption and in uence peddling. This program is driven by a strong commitment from senior management, managed by the Governance, Risks and Compliance Department and run at local level by a network of specialists in the lines of business and regions. The program comprises a set of measures, adapted to the Company and corresponding to the eight pillars stipulated by the “Sapin II” law: a Code of Ethics (supplemented by internal policies and procedures distributed to all employees, any breach of which may give rise to disciplinary sanctions); risk mapping for corruption and influence peddling, updated yearly and aligned with the most recent recommendations of the supervisory authorities; a system for verifying the integrity of third parties using a risk-based approach; a training program for employees and suppliers/subcontractors most at risk; an internal alert system; an accounting control plan and a system for monitoring the effectiveness of the program, including rst, second and third-level controls. 2023 ACTIVITY AND SUSTAINABILITY REPORT - 83 EDITORIAL > 1. PROFILE AND AMBITION > 2. CSR POLICY > 3. ENVIRONMENT > 4. SOCIAL > 5. ETHICS > 6. TABLE OF INDICATORS
RkJQdWJsaXNoZXIy NzMxNTcx