The Alert System has been established so that all cases of suspected misconduct are reported to Ceva Santé Animale and its subsidiaries and affiliated companies, (collectively “Ceva”).
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What Cases can be Reported ?
The Alert System can be used to raise concerns about suspected misconduct. Examples of misconduct include potential violation of a treaty, a law, a regulation, our Code of conduct or policies of Ceva. This infringement may be ongoing at the time you decide to report it, have occurred in the past or is likely to occur. The attempts to conceal a violation are also covered by this Policy and can be reported.
If you experience, observe or suspect misconduct, you are encouraged to report it !
Who can Raise an Alert ?
The Alert System is available to :
- employees and former employees of Ceva
- external and occasional collaborators such as employees on secondment and temporary staff, agents, representatives, etc.
- candidate who has applied for a job;
- shareholders, partners, and holders of voting rights in the Group’s decision-making bodies;
- third parties with whom the Group has or has had business relationships in the past (business partners, suppliers, distributors, representatives, customers, subcontractors, etc.)
How to Raise an Alert?
Users of the Alert System must act in good faith and refrain from deliberately making false accusations. Acting in good faith means a report is made without malicious intent or seeking personal benefit of any kind and that the person making the report has good reason to believe that the allegation is true.
Any person who willfully makes false or misleading declarations may be subject to disciplinary measures or legal proceedings in accordance with applicable laws and regulations. Persons who act in good faith will not be subjected to disciplinary measures or prosecution if their declarations are subsequently found to be irrelevant.
You can report your alert anonymously. However, we encourage you to reveal your identity as it may be difficult, or in some cases impossible, to fully investigate anonymous reports. If you choose to report anonymously, you will be informed of the action taken on your report while retaining the benefit of your anonymity. For example, you could provide an e-mail address that does not allow you to be identified, or a postal address.
Please provide as many details as possible, so as to permit a clear understanding and investigation of the facts. Information shall be factual and presented in a neutral and objective way. and directly related to the purpose the alert. The personal data provided within the alert shall be adequate, relevant and limited to what is strictly necessary.
Through this process, the confidentiality of your identity is guaranteed. Your identity will not be disclosed to any of the individuals mentioned in your alert or to any other person without your permission, unless otherwise required by law or regulation. Your identity and information about your report will only be shared with a limited number of people and only with those who need to be informed (Ethics & Compliance Department and the investigation team).
No retaliation by an employee of the Group or the Group itself against a person who in good faith reports a potential violation or provides assistance to the teams charged with the investigation will be tolerated.
The Alert System, by its nature, will process personal data.
In this context, Ceva, as data controller, will access your personal data and the personal data of the persons subject or named in the alert.
The legal basis for the processing of personal data is our legal obligation under the Sapin II law (articles 6 and 17.II.2°) and on Ceva’s legitimate interest, i.e. to enable the identification and processing of a rule violation that would be detrimental to the company’s interests.
In accordance with the regulations on the protection of personal data, any person has the right to access the data that concerns him or her and to request that such data be corrected taking into account that an implicated person may not obtain information regarding third parties, such as the identity of the person who submitted the report, on the basis of such rights of access.
You also has the right to object, depending on the context in which the alert was file as ask for the limitation of the processing of its personal data
To exercise these rights or for any request relating to your personal data, any person can send an email to email@example.com.
More information on the Alert System and the personal data processing is available on the Reporting Policy (available at the bottom of the page)