You can use the our whistleblowing system if you are: 

• An employee (employees, shareholders, managers and executives) including external and occasional workers (temporary workers, apprentices, trainees);
• A person  whose employment relationship with the Elior Group has ended, provided that the information was obtained within the framework of this relationship;
• A person who has applied for a job within Elior Group, provided that the information was obtained in the context of this application;
• The co-contractors of the Group as well as their subcontractors.

• Breach of competition rules (for example: sharing any confidential information with competitors or agreeing on prices with competitors)
• Corruption (for example: offering/receiving sums of money or gifts in exchange of obtaining/granting a contract)
• Influence peddling (for example: paying a third party to use his/her influence with a public authority or administration to obtain an undue advantage)
• Conflict of interest (for example: selecting as a supplier a company in which one of the family members of the decision maker works)
• Money laundering / Financing of terrorism
• Fraud
• Moral and/or sexual harassment and discrimination
• Threats to the physical integrity of individuals
• Data breaches / GDPR violations
• Breaches of hygiene and/or quality standards
• Environmental harm or adverse impacts on human rights and fundamental freedoms
• Breaches of occupational health and safety rules or indecent working conditions.
• Any other violation of a law, regulation, or breach of Elior Group internal rules (e.g., the Ethics Principles or the Integrity Guide)

An acknowledgement of receipt (indicating the date and time the report was received) will be sent to the reporting author by the Case Manager within seven working days of the report being submitted. The Case Manager will verify that the reported facts fall within the scope of the reporting system and that they are sufficiently substantiated to warrant further review.

No later than three months after the acknowledgement of receipt of the report, the reporting author will be informed by the Case Manager of the decision regarding the follow-up to be given to the report:
 

• The report may be closed if it is deemed inadmissible. The notification will specify the reasons for the closure (e.g., the report falls outside the scope of the reporting system or is insufficiently documented). Where appropriate, the reporting author will be directed to the relevant internal contact.
• A decision may be made not to initiate an investigation where the report is admissible, but the available information is sufficient to confirm or refute the allegations without the need for further inquiries. Where appropriate, suitable remediation measures will be implemented.
• Or an investigation may be opened where the report is admissible and further inquiries are required to verify the allegations and, where appropriate, determine the suitable remediation measures to be implemented.
   

In accordance with the law, no retaliatory measure against a whistleblower shall be tolerated.
 

Whistleblowers benefit from a protected status designed to safeguard them against any adverse consequences resulting from a report, provided that the report was made in good faith and that the whistleblower had reasonable grounds to believe that the report was necessary to protect the interests at stake (such as the health and safety of employees, customers, the protection of Elior Group’s integrity and reputation, etc.).

Accordingly, Elior Group prohibits any form of retaliation, threat of retaliation, or attempted retaliation, including but not limited to the following:
 

• Suspension, layoff, dismissal or equivalent measures;
• Demotion or denial of promotion;
• Reassigning to a less desirable position, change of place of work, reducing or changing pay or hours;
• Suspension of training;
• Negative performance evaluation or work certificate;
• Imposed or administered disciplinary measures, reprimand or other sanctions, including financial sanction;
• Coercion, intimidation, harassment or ostracizing;
• Discrimination, disadvantageous or unfair treatment;
• Failing to hire;
• Failure to rehire or early termination of a fixed-term employment contract or a temporary contract;
• Harm, including damage to reputation, in particular on an online communication service, or financial loss, including loss of business and loss of income;
• Blacklisting (sector or industry level);
• Early termination or cancellation of a contract for goods or services;
• Cancellation of a license or permit;
• Improper referral to psychiatric or medical treatment.

Important: facilitators (third parties who aid the whistleblower to make a report, such as unions or NGOs) and the relatives and colleagues of the whisleblower are also protected under this Charter and are entitled to the same level of protection as the whistleblower.

Elior Group guarantees the confidential
handling of all information collected through
the reporting system, which records only the
personal data provided by the whistleblower
or required for the processing of the report,
including all or part of the following
information (depending on the data
submitted):

• The identity, contact details and position of the whistleblower;
• The identity, position and contact details of any individuals who assisted in submitting the report, where applicable;
• The identity, position, and contact details of the persons concerned by a report;
• The identity, position, and contact details of persons interviewed as part of the report handling process, where necessary;
• The identity, position, and contact details of persons involved in the receipt or processing of the report, where necessary;
• The reported facts; 
• The information collected during the verification of the reported facts;
• The report on the verification activities carried out and the follow-up actions taken in response to the report.

Data collected within the European Economic Area will not be transferred to a country outside the European Economic Area unless there is an adequacy decision in place.

The identity of the whistleblower is disclosed within the company, where necessary, only to those individuals who need to know it for the purposes of verifying or handling the report and any resulting actions, and solely after they have signed a specific confidentiality undertaking. Likewise, the whistleblower's identity is under no circumstances disclosed to the individuals concerned by the report.

Except in the circumstances described above, any information that could identify the whistleblower may not be disclosed without their consent, unless disclosure is required by a judicial authority or to comply with a legal obligation.

Similarly, any information that could identify a person named in a report may not be disclosed, except to a judicial authority or to comply with a legal obligation, until the well founded nature of the report has been established.

The data is collected and stored within a restricted-access tool hosted by the external service provider. Access is limited to the relevant licensed Case Managers, who can log in using a username and password.
 

If a report is submitted through a trusted internal contact, that person will be able to answer any questions relating to data retention arrangements and, more generally, to any matters concerning the collection of personal data.
The data collected will be retained only for as long as is necessary to process the case under review.

The data will be deleted as soon as its retention is no longer required for legal purposes (for example, for the duration of legal proceedings where such proceedings have been initiated) or, where possible, retained in an anonymised form (i.e., with personal data removed or irreversibly neutralised within the retained information).

Furthermore, in accordance with the General Data Protection Regulation (“GDPR”), any individual identified within the reporting system may access the personal data concerning them and, where applicable, request that such data be corrected or deleted.

They may also object to the processing of their personal data, but only within the limits set by Article 21 of the GDPR (meaning that legitimate and compelling grounds may override the interests, rights, and freedoms of the data subject).

However, under the right of access, they may not obtain information relating to third parties, and in particular the identity of the whistleblower.

For any information or to exercise rights relating to the protection of personal data, the whistleblower or any other data subject may contact: gdpr-contact@eliorgroup.com.

In accordance with the GDPR, the Case Manager shall inform the person concerned by a report within a reasonable period of time, which should in principle not exceed one month. The person concerned shall be informed of the allegations made against them, as well as of the procedures for exercising their rights of access and rectification.

However, information may only be provided to the person concerned after the implementation of any necessary protective measures, where such measures are
essential, in particular to prevent the destruction of evidence required for the processing of the report. Furthermore, the information provided to the person concerned shall not contain any details relating to the identity of the whistleblower or of any third parties.
 

Elior Group also undertakes to apply the principle of proportionality in the event that sanctions are imposed following the confirmation of the reported facts.