Whistleblowing procedure.

This page is a translation, provided for information only. Only the French version is legally binding: in the event of any contradiction, discrepancy or doubt as to interpretation, the French version shall prevail.

Preamble

In addition to its internal Code of Ethics and to strengthen its ethical commitments, Mistertemp’ group (hereinafter “the Group”) has set up a whistleblowing procedure (hereinafter the “Procedure”) so that anyone can report a situation that is inappropriate or that breaches applicable laws and regulations.

The Procedure, which applies to the parent company and its subsidiaries in France, enables all employees and external stakeholders to report, confidentially, acts contrary to the internal Code of Ethics, laws and regulations and, more generally, to raise their concerns responsibly, without fear of retaliation.

The purpose of the Procedure is to enable the Management of Mistertemp’ group to detect a risk situation and to act at an early stage, or even preventively, before the risk materialises.

What can be reported?

Any fact concerning the following may be reported:

• a breach or suspected breach of the internal Code of Ethics or of the Internal Regulations,
• a criminal offence (for example corruption, fraud, anti-competitive practices), as defined by local laws;
• a breach of an applicable law, regulation or international treaty;
• a threat or harm to the public interest;
• an incident relating to human rights, health and safety, or the environment.

For example, the following may be reported:

Corruption, anti-competitive practices, discrimination, fraud or harassment at work.

Any report falling outside the scope defined above will be rejected and the data collected on that occasion will be deleted.

Anyone wishing to report conduct falling outside the scope of the Procedure should refer to their usual contacts (line managers, relevant departments within Mistertemp’ group).

Who can make a report?

Any permanent or temporary employee (fixed-term contracts, interns, etc.), temporary agency workers, or people outside the company (clients, service providers, suppliers, subcontractors) may make a whistleblowing report.

To do so, the whistleblower must:

• have personal knowledge of the facts reported, whether in a professional or a non-professional context: this is not about reporting facts observed by others, but facts observed personally and which the whistleblower reasonably believes may constitute reportable facts;
• act selflessly: the whistleblower must act to defend the general interest and not on their own behalf; the report must not grant them any advantage, and the whistleblower must not be paid in return;
• act in good faith: misuse of the procedure may expose its author to disciplinary sanctions or legal proceedings. However, use of the procedure in good faith, even if the facts later prove inaccurate or lead to no further action, will not expose its author to any disciplinary sanction.

Using the whistleblowing procedure is a right that the people concerned exercise freely; its use nevertheless remains optional. Consequently, not making a report will have no consequences for employees.

How to report? [Ethics hotline]

There are several ways to report:

• by informing one’s line manager, orally or in writing;
• by sending an email to: alerteprofessionnelle@mistertemp-group.com

Although the whistleblowing procedure allows misconduct to be reported anonymously, people using the Procedure are encouraged to identify themselves, and they are guaranteed the utmost confidentiality (which may only be lifted in the context of legal proceedings).

The facts collected must also be strictly limited to the areas covered by the Procedure.

Confidentiality

The people responsible for collecting and handling reports are bound by a strict duty of confidentiality regarding:

• the identity of the whistleblower;
• the identity of the people targeted by the report;
• any documents provided as part of the report.

Protection of whistleblowers

Using the whistleblowing procedure in good faith, even if the facts later prove inaccurate, cannot expose the author of a report to sanctions. However, any abusive report may lead to disciplinary sanctions and/or legal proceedings.

If the whistleblower believes they are subject to retaliation, they must report it immediately via the hotline.

Handling of reports

The whistleblower reports an incident, anonymously or not, in person, by phone or by email.

When the report is made by email, an acknowledgement of receipt is sent as soon as possible.

The report is then analysed by the internal officer responsible for collecting and handling reports.

Once the report has been found to fall within the scope of this policy, it is followed by an investigation carried out through a confidential, objective and thorough process.

The purpose of the investigation is to determine whether or not the report is substantiated (confirmed ethical breach or misconduct), taking into account the facts presented in the report and the information made available during the investigation period. It also aims to determine, ultimately, the corrective measures to be taken to remedy the reported incident, where applicable.

Once the investigation is complete, an investigation report is drawn up. The whistleblower must be informed of the outcome of the handling of their report (i.e. whether it was found to be substantiated or not).

At the end of the investigation, whether the allegations were found to be substantiated or not, the whistleblower’s personal data will be protected.

If the investigation confirms internal control weaknesses, fraudulent conduct or significant deviations, appropriate corrective and/or remedial measures will be taken to address the report:

• strengthening of the Group’s policies, procedures and controls;
• assistance from Human Resources or others for the author of the report;
• ethics training;
• disciplinary sanctions or legal proceedings, where applicable.

Retention of collected data

If it is decided not to initiate disciplinary and/or legal proceedings once the facts have been established, the information relating to the report is destroyed within TWO (2) months of the date on which the investigation is closed.

If it is decided to take any action to stop the conduct in question and to initiate disciplinary and/or legal proceedings, the data collected will be kept until the end of the time limits for litigation. The data may then be archived in accordance with applicable legal provisions.