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Compliance and ethics

WHISTLEBLOWING POLICY OF AMARANTE INTERNATIONAL

 

Amarante International has established an internal whistleblowing system that enables its employees, consultants, subcontractors, outsourced staff, customers and other external stakeholders (such as local communities or NGOs) to warn the company about any potential violations of the applicable legal and regulatory standards, or of the internal rules established at Amarante International's initiative. 

Amarante International pays particular attention to respect human rights, as well as the specific requirements included in the International Code of Conduct for Private Security Providers (ICoC) and the company’s own Code of Conduct and Ethics, to which it is fully committed.

Therefore, this whistleblowing system constitutes a complementary and voluntary measure that does not replace the traditional reporting channels that already exist within Amarante (line management, Human Resources Manager, Quality Manager or statutory auditors).

Facts, information or documents covered by national defence secrecy, medical secrecy or the secrecy of relations between a lawyer and his client are excluded from the protection granted to whistleblowers.

 

Procedure

Alerts can be sent confidentially by email to compliance@amarante.com. 

An initial response will be provided by a member of Amarante International's Ethics Committee within five working days of receipt of the message by the company.

 

Commitments of the whistleblower

The whistleblower will act in good faith, without malice, malicious intent or to obtain a personal reward or compensation (other than appropriate compensation, if any).

Otherwise, he or she may not benefit from the whistleblower's protection and may even be subject to criminal prosecution as per the applicable regulations.

The whistleblower must have direct knowledge of the facts reported (and not through the intermediary of a third party).

 

Commitments of Amarante International

No negative action will be taken against a person who has used the whistleblowing mechanism in good faith.

Amarante International guarantees that all communications will be treated confidentially and anonymously. With the exception of judicial authorities, any element that could identify the whistleblower will only be disclosed with his or her consent. Facts will only be disclosed with the issuer's authorization.

Amarante International will promptly and impartially investigate the constitutive elements of the whistleblowing case, under the strict respect of the legal rules applicable for the protection of the source.

Amarante International will cooperate in all circumstances with any official investigations that may be undertaken.

Amarante International will take immediate disciplinary action if the facts reported justify it, including as applicable the exclusion of employees, consultants or sub-contractors.

Amarante International will ensure compliance with the provisions of the General Data Protection Regulation (EU GDPR) of 2016, the French Data Protection Act of 1978 and the CNIL reference frame of 2019. 

Only the data necessary for the purposes of processing the case referred by the whistleblower will be collected and processed. Any new use of the data will respect the principles of personal data protection. All personal data will be destroyed within two months of the completion of the internal investigation.

In addition to the present whistleblowing mechanism, employees, consultants, subcontractors, outsourced staff, clients and other external stakeholders may, if they wish, contact the International Code of Conduct Association (ICoCA) directly through its website or submit their case to the French ombudsman (Défenseur des droits) in order to be directed to the appropriate body to transmit the case.