Report a Concern

/!\ If you are an Ekimetrics employee and wish to make a report, we invite you to follow our internal policies and procedures that are available in Confluence.

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Overview of reporting 

Should you identify, in good faith, any of the following conducts by an Ekimetrics employee or an employee of any third parties associated with Ekimetrics, we encourage you to report it:  

• A violation of applicable laws or regulations;
• A crime (including, but not limited to, aggravated theft or attempt of such) or an offence (including, but not limited to, tax fraud, forgery, corruption, misappropriation of corporate assets, breach of trust, illegal taking of interest, influence peddling, malicious telephone calls or messages, threats, sexual or moral harassment, discrimination of any kind, extortion, blackmail, swindling, illegal use of public funds);
• Behaviours contravening the Ekimetrics Anti-Corruption Code of Conduct;
• A threat to or serious harm to the public interest;
• A violation or concealment of a violation of a regularly ratified or approved international commitment;
• Commercial and/or service-related concerns; 
• Recruitment-related concerns. 

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Reporting can be done confidentially by reaching out to speak-up@ekimetrics.com.

For any concerns related to commercial, service, or recruitment matters, unless they involve serious non-compliance concerns (including, but not limited to, discrimination, harassment, illegal activities), we invite you to reach out to us via our contact form, available at Contact.  

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Reports should include sufficient details, such as dates, names, and functions of the persons involved, Ekimetrics entities and any third-party entities involved, a description of the facts and circumstances, any relevant supporting documentation/evidence (if any), and your contact information to be used to communicate with you. 

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Handling of reports 

1. Acknowledgment

• We’ll acknowledge receipt of the report without undue delay.

2. Assessment and Investigation

• We’ll verify the admissibility of the report within a reasonable timeframe. We will consider whether the report is submitted in good faith and whether it involves direct financial compensation. We will also consider whether the report is factual and complete and may request further information before beginning the investigation. 
• We will inform the reporter whether the report is considered admissible or not. If not, we will provide the reasons for its inadmissibility. 
• If the report is admissible, appropriate resources will be allocated to investigate it and to determine the appropriate course of action. We may request further information and assistance from the reporter and from other relevant individuals during the investigation. We will only involve those individuals who need to be involved and will ensure the investigation remains confidential. 

3. Response and Resolution

• We will provide the reporter with a written response within a reasonable timeframe, confirming that the report has been processed and outlining the outcomes of the investigation and any measures (including corrective and/or mitigating measures, if any) taken or to be taken. We will also inform the reporter of the closure of the procedure.

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Protections for those who report 

Confidentiality

Information revealing the identity of any physical person reporting or the identity of the person concerned by the report as well as the information received by the recipients of such report and the restricted team in charge of the investigation (if any) will remain strictly confidential. 

Information enabling to identify the reporter may not be communicated to any third-parties, other than to the judicial authorities, unless the reporter’s consent has been obtained. 

Information which makes it possible to identify the person concerned by a report may not be communicated to any third-parties, other than to the judicial authorities, unless it is established that the report is admissible, and the information disclosed is based on sufficient and precise grounds. 

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Protection against reprisals 

Individuals reporting in good faith, who have sufficient and reasonable grounds to believe that the information disclosed constitute a reportable fact, and those who have been requested to assist in the investigation will be protected from reprisals and other detrimental treatment (including dismissal, disciplinary sanctions, any form of harassment, intimidation, discrimination, threats…). 

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Protection of personal data

In order to handle the submitted report, determine whether it is admissible, perform the proper verification and give feedback, Ekimetrics, as a data controller, may have to process personal information (such as the name, contact details, position of the reporter or other individuals concerned by the report or interviewed in the context of the investigation, information about the context/facts revealed in the submitted report…). Only strictly necessary information will be collected and processed for such limited purposes.

The legal basis Ekimetrics relies on to perform such processing are the following: legitimate interest, compliance with legal obligation, and consent of the reporter. 

Only a limited number of duly authorized persons (as regards their specific functions or because they are members of the restricted team in charge of conducting the verification) will have access to such information, which will not be communicated to any third party, except in the specific circumstances and subject to the conditions set out in the previous sections. 

Your personal information will be kept for the duration of the verification and investigation process and no longer than is necessary for the purposes for which such information is collected and processed. In practice:

• If the report is not considered admissible, information submitted are deleted as soon as possible and in any case within 2 months of receipt.
• If no action has been taken in response to the investigation, the elements recorded which make it possible to identify the reporter and the persons concerned by the report will be permanently destroyed within 2 months of the closure of the verifications.
• Where Ekimetrics may have a legitimate interest to keep it (e.g. as evidence in the event disciplinary measures are decided or in case of a dispute or to be able to answer any request from a competent judiciary or regulatory authority in case of an investigation), such information may be retained for a longer period, which cannot exceed the limitation periods applicable locally. 

Where you are a data subject under the European General Data Protection Regulation (GDPR), you have the right to request access to, rectification or erasure of your personal data, or restriction of processing, a right to object to processing (in the conditions set out in the GDPR). Should you wish to exercise these rights, please address your request to: speak-up@ekimetrics.com.

If you have any concerns about our use of your personal information, you can make a complaint to the Group DPO: data.protection@ekimetrics.com.

You can also complain to your local data protection supervisory authority.