Speak Up explained - Expolink · For example, the investigator should not be a colleague, the manager or the direct report of the accused. If the Case Manager determines at any time

Speak Up explained

2 Speak Up explained

01 Why we Speak Up

02 What should you do when you think our values, policies or the law are violated?

03 How can you raise a concern?

04 SHV’s Key Speak Up principles

05 What happens after you make a report?

06 SHV’s investigation principles

07 Data protection

08 More information

Contents


At SHV we believe in acting with integrity, in line with our

values, policies and the law, so our colleagues, clients and

partners know they can trust us. And if there’s a risk we

may fall short, it’s essential that you speak up and help

us resolve any concerns. You need to feel safe to raise a

concern and we need to make sure we treat everyone

involved with respect.

Ideally, you would discuss any concerns directly with the

person involved, your manager, HR or an Ethics & Compliance

Officer (ECO). But if you don’t feel comfortable with any of the

above options, you can use Speak Up.

Speak Up is SHV’s confidential whistleblowing line. Managed

by SHV Holdings. This manual explains what that means

to you, from how to raise a concern to what happens next.

It can be difficult or stressful to highlight a violation of our

Shared Values, our policies, or of the law, but it’s our collective

and individual responsibility to do so.

01 Why we Speak Up

Share your concernsDo what’s right


If you have a concern, it’s important that you raise it.

Don’t keep it to yourself or ignore it.

While you should try to raise this with those directly involved,

we know that isn’t always easy or possible. In some cases,

the responses you receive may not resolve your concerns.

In those cases, you can use Speak Up.

Whenever you think, ‘I’m not sure this is right’, ask

the question or raise a concern. Some examples are:

• You feel a colleague is treating you poorly

• You see unsafe working conditions

• You suspect someone of stealing

• You suspect a colleague is taking bribes

• You believe a colleague is being dishonest



What sort of concerns can I raise?You can use Speak Up when you want to raise a concern about

a violation or potential violation of:

• SHV’s Shared Values

• SHV, Group or Business Unit policies, procedures, regulations

and guidelines, including any applicable Code of Conduct

• Local, national and international laws, rules or regulations

Who can raise a concern? Anyone who feels or suspects that something isn’t right can raise

a concern using Speak Up. This includes employees, contractors,

former employees, business partners and customers.

When should I avoid using Speak Up?• Please contact your manager or HR department if you

disagree with management decisions, such as promotions,

re-organisations and salary negotiations, unless these

decisions violate our policies or the law.

• For reporting serious emergency incidents, such as safety,

medical or travel incidents. Please use local emergency

channels in these cases.

• Regarding customer complaints. The customer service

department should deal with these.



Give feedbackWe should all welcome prompt, honest feedback.

So first try to raise your concern with the person involved

as soon as possible.

Or

Inform management, HR or ECOIf you believe that the situation can’t be resolved by talking to

the person involved, you can speak to your manager or next

higher manager instead. You could also talk to your HR

manager or the ECO in your Group. They will address your

concern in a serious, confidential and objective way, consistent

with our Shared Values.

Or

Use Speak UpIf you suspect a potential violation of our Shared Values,

policies or the law and feel uncomfortable taking any of the

actions above, you can use Speak Up.

You can:

• Call the hotline

• Use the website to make an online report shvspeakup.com



Use an external reporting channel In addition to making an internal report, local law may offer

you an option to report to the appropriate local authorities. SHV

encourages you to raise your concern through Speak Up first.

That gives us an opportunity to collect the facts and assess the

risks and consequences. We will address your concern in

a serious, confidential and objective way, consistent with our

Shared Values.

Good faith SHV welcomes all concerns raised in good faith, even if

the report turns out to be unfounded. However, if we find

an employee has deliberately falsified a report or has acted

inconsistently with SHV’s Shared Values, he or she will be

subject to disciplinary action, including possibly terminating

his or her employment.


Or


To provide reporters with comfort and protection

when they raise a concern, we adhere to the following

key principles:

Confidentiality

All reports will be handled confidentially to the maximum extent

possible. When the reporting employee has given his or her

name, their name will only be shared on a need-to-know basis

with specific investigation team members.

Anonymity

When you use Speak Up, you do not need to give your identity,

although we do ask you to consider it.

If we need additional information, an anonymous report is

harder to investigate. Do remember that some countries have

legislation in place that prevents anonymous reporting.

Non-retaliation

SHV has a strict policy of non-retaliation against reporting

employees. Anyone raising a concern must be treated as if no

report was filed. We will take no disciplinary measures or other

steps against an employee raising a genuine concern, even if

this concern later turns out to be unfounded, mistaken or

misguided. We will not tolerate any violation of this principle

and if this occurs, will treat this as a separate incident.

04 SHV’s Key Speak Up principles


1 ReportingWhen you file a report, either through the Speak Up phone

line or via web reporting, this will be registered in the case

management system (CMS).

2 Initial reviewThe Ethics Program Officer (EPO) of SHV assesses the report

and considers:

• Whether the report is in line with local legislation, for example

local laws may restrict people reporting anonymously, as well

as the type of allegations which may be reported by law.

• The information available:

- What happened?

- Where did it happen?

- When did it happen?

- Is it an ongoing issue?

- Who is involved?

- Who was consulted before Speak Up was contacted?

• Any related reports (location, issue, possible persons

involved).



3 Classifying the reportA report is given a priority A, B or C status.

Priority “A” – initial follow up immediately. These reports

require immediate attention. They involve an immediate threat

to people, property or the environment.

Priority “B” – initial follow up within FIVE business days.

These reports involve serious or time-sensitive issues, or

those with serious potential legal ramifications, but that does

not represent an immediate threat to people, property or

environment.

Priority “C” – initial follow up within TEN business days.

These reports involve routine issues and generally do not

require an immediate response.

4 Assigning a reportEach business day, the EPO of SHV will check incoming

reports and make sure these reports are assigned to the best

person to deal with your report (Case Manager) during the next

business day, except for priority A reports that get immediate

attention. The case will be handled at least one management

level up from where the issue reportedly exists.

5 MonitoringAfter a report has been assigned to a local Case Manager

the ECO will monitor whether reports are dealt with in a fair

and timely manner.



6 Investigation Investigation of the cases will be done by a Case Manager.

7 ReportingThe Case Manager will report findings and follow up on cases

in the CMS. The Case Manager will register (preliminary)

investigation notes within 30 days.

8 Feedback to reporterAs a reporter you can call the phone line or log in to the

Speak Up website with your case ID, which you have received

after submitting your report, to get regular updates during

the investigation and to be notified once the investigation

is closed and the report finalised.

9 Actions and sanctionsIf the report turns out to be substantiated, partially or in full,

SHV or the relevant Group will take appropriate actions.



IndependenceThe Case Manager must be sufficiently independent so

they can perform the investigation in an objective manner.

For example, the investigator should not be a colleague,

the manager or the direct report of the accused.

If the Case Manager determines at any time during

the investigation that a (potential) conflict of interest has arisen,

the Case Manager should contact the ECO immediately

to discuss the conflict and review its role.

Impartiality The Case Manager must have an impartial attitude towards

the investigation and the accused. All relevant aspects the

Case Manager encounters during the investigation should be

included in his or her professional assessment.

ProportionalityThe Case Manager must choose investigation measures

depending on the phase of the investigation, that are

proportional to reaching the investigation goal, to determine

whether the raised concern is a violation. Investigation

measures should not have a disproportional impact on the

privacy of the accused. The privacy interests of the accused

should be adequately weighed against the measures of

investigation.



Fair hearingThe Case Manager must hear the reporter, if he or she has

identified himself / herself, and the accused to understand his

or her version of the facts. The Case Manager must also give

the accused the opportunity to respond to the investigation

results and refute any investigation findings, prior to issuing

the final investigation report.

Any person under investigation will be notified, after safeguarding

relevant evidence if necessary, unless such notification could

jeopardise the investigation.

Both the reporter and the person or persons under investigation

have the right to be heard during the investigation and to have

a trusted person present at the hearing.

Reasonable timelinesThe investigation should be conducted within a reasonable

timeframe. Both the accused and the reporter must be informed

and updated on the expected due date of the investigation

report and closing of the case.



07 Data protection

What reasons will you process personal data for?Personal data is processed for handling and investigating

Speak Up reports.

What happens with the personal data in the system?Speak Up offers employees the opportunity to report their

concerns in case regular communication channels are

insufficient. The concerns are entered into the system of

Expolink, an external company that specialises in complaints

handling. SHV has made strict agreements with Expolink about

the confidentiality and security of Speak Up.

Using specific secured software, Expolink will inform SHV of

any concerns reported. Expolink uses the information obtained

for no other purposes. The EPO sends the information to

the local Case Manager. The ECO has access to the system

for monitoring purposes.

What does SHV use the collected personal data for?SHV uses the personal data collected through Speak Up

to process the concern, investigate relevant facts and follow

it up in a timely and correct manner.

Complaints or questions?If you have any complaints or questions about the way SHV

uses your personal data, please contact the SHV Corporate

Ethics & Compliance Director: [email protected].

For more information read our Privacy Statement.


08 More information

If you have any questions relating to Speak Up, please contact

your manager, HR manager or ECO.

Alternatively, you can contact the SHV Ethics & Compliance

department at [email protected]

Concerns about the general functioning of Speak Up and the

Speak Up investigation process are important and should be

reported to the SHV Corporate Ethics & Compliance Director.

This can be done through [email protected].

“ This doesn’t feel right...”

We trust you to talk to usYou can trust us to listen


Share your concernsDo what's rightshvspeakup.com

Documents

Speak Up explained - Expolink · For example, the investigator should not be a colleague, the manager or the direct report of the accused. If the Case Manager determines at any time