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External Whistleblowing System
As part of its commitment to strengthen its ethical commitments and to provide tools accessible to all to report a situation that is inappropriate or does not comply with our principles or applicable laws and regulations, Stuart has created this whistleblowing system available to all stakeholders (users, customers, suppliers, subcontractors, unions, NGOs, etc.). This system complements existing internal channels and strengthens Stuart's approach to ethics and compliance.
What is a Whistleblowing system?
A whistleblowing System is a mechanism placed at the disposal of Stuart’s employees and stakeholders for reporting actions or behaviors that may compromise individuals’ integrity and/or rights, that may affect Stuart activity, and/or create serious liability (health and safety, environment, human rights, individual rights, privacy. etc.).
When should I use the Whistleblowing system?
When you witness or are aware of a behavior or actions that you believe to be misconduct, illegal and not in line with ethics standard and principles, as well as all other violations of laws and regulations or any incident relating to : Fraud, Data protection, Human rights (including Modern Slavery and Human traffichink), Anti Corruption and Anti Bribery, Environment, Antitrust, Harassment, Tax evasion, Health & Security, International sanctions, Discrimination, any crime, etc…
Who is concerned ?
This alert system is intended for all Stuart stakeholders who are victims or witnesses of an incident or behavior as listed above : any third party involved with Stuart, users, subcontractors, suppliers, partners, clients, end-consumers, unions, NGOs, etc…
An internal Whistleblowing channel is also in place to facilitate the communication of irregular behavior within Stuart itself, its employees, or third parties that have some relationship with the company.
How does it work?
The Whistleblowing System offers the whistleblower two possibilities:
- entering the information relating to their Alert on the online whistleblowing platform, part of the Whistleblowing System accessible at the following address: www.safecall.co.uk/clients/stuart; or
- sharing their Alert information by phone, by calling the following toll-free number: 00 800 7233 2255
Stuart provides, with Safecall, an independent confidential reporting line where you can raise your concerns and be assured they will be fully addressed. Calls are handled by skilled staff and will be treated in complete confidence. A report will be sent to the Ethics Officer, or the Chief Compliance Officer.
Safecall will not disclose your name to Stuart if you wish to remain anonymous. Although, it is recommended that you identify yourself in order to facilitate the exchange of additional information, to facilitate the review of the Alert and to ensure your protection against possible retaliation.
You can contact Safecall at any time, the Safecall line is available 24/7, 365 days.
To understand how the alert will be handled by Safecall and the Ethics Officer, or the Chief Compliance Officer, please consult the Procedure.
How are the whistleblower and the other persons concerned protected?
Confidentiality and integrity of information relating to the Alert
In order to protect the identity of the whistleblower and the information relating to the Alert, any information relating to an alert communicated by the whistleblower must be:
- strictly confidential; and
- protected with regards to its integrity.
To guarantee this confidentiality and integrity, the persons authorised to have access to the information :
- are limited in number, to the strict minimum;
- are formally authorised to read and treat the Alert;
- have, due to their position within Stuart or otherwise due to their status, the competence, authority and sufficient means to carry out their tasks;
- are able to demonstrate their impartiality and do not present in a conflict of interest; and
- have received proper training.
The identity of the person(s) targeted by the Alert shall also be protected in this respect.
Protection against retaliation
Any person involved directly or not to the Alert or the whistleblower may benefit from protection against retaliation.
Any type of retaliation in response to an Alert is prohibited, including threats or attempts at retaliation.
Protection against retaliation also protects the concerned individuals from legal action and possible prosecution based on information relating to their Alert.
Stuart has a zero-tolerance policy for retaliation. Any person directly or indirectly engaging in retaliation against protected persons shall be subject to disciplinary and/or legal action.
Some cases are excluded from protection. You can consult the Procedure to know more.
Right to Alert
When they become aware of a wrongful act, any person concerned by this Procedure is free to file an Alert or not. Failure to file an Alert shall not lead to any sanction.
When using the Whistleblowing system in good faith, you are not at risk of any penalty whatsoever, even if the facts prove to be inaccurate or do not result in any action being taken. If an employee believes himself to be subject to pressure for using the warning device, the employee must report it.
In the event that after a detailed analysis, it appears that an employee reported a breach knowing that it was a false complaint in order to harm another employee or stakeholder, Stuart may exercise its disciplinary power over the employee in accordance with the regulations of each site.
Protection of personal data
Information on the processing of information relating to a natural person that can be used to identify, directly or indirectly said person is available on the landing page dedicated to Stuart, accessible at the following link: www.safecall.co.uk/clients/stuart.
As a reminder, personal Data – whether it concerns the whistleblower, the person targeted by the Alert or any person identified in connection with the Alert or its handling – may be processed within the meaning of the General Data Protection Regulation.
These persons shall have a right of access, rectification, opposition, where possible, and erasure of their Personal Data. Persons whose Personal Data is thus processed may exercise their rights by contacting email@example.com.