Raising Concerns FAQs

1. What is Whistleblowing and who can use the concerns line (incl. Whistleblowing)?

Whistleblowing refers to the reporting of an alleged irregularity committed by an employee or supplier outside the daily management reporting line. A whistleblower is a person who has obtained information on offences in an employment or professional context in Alter Domus and reports the alleged irregularity committed, including, but not limited to, employees, self-employed persons, shareholders, members and individuals associated with the administrative, management or supervisory body (including non-executive members), individuals working for or under the supervision and direction of contractors, subcontractors, suppliers, consultants, individuals gaining work experience, ex-employees, potential future employees based on concerns relating to the recruitment process or pre-contractual negotiation, volunteers, trainees and traineeship workers.

2. What is a concerns line (incl. Whistleblowing)?

A concerns line is a framework designed to ensure that concerns and irregularities can be reported, carefully and impartially reviewed and, where appropriate, investigated. It is the communication channel that enables the concerns framework through anonymous and nominative communications combined with security and integrity controls for the information and processing of personal data. It is the preferred means for receiving Whistleblowers’ Communications.

3. What may one communicate through concerns line (incl. Whistleblowing)?

Information about abuses, infringements or malpractices in an employment or professional context affecting the general interest of Alter Domus and/or the public. Ethics and compliance matters may also be raised via the concerns line.

While a variety of concerns may be raised via this avenue (e.g. complaints and/or claims), it is intended that those communications included in the scope of the Directive (EU) 2019/1937 and in the corresponding transposition into local law, will exclusively be covered by the protection measures established by law.

Some examples of reportable infringements are:

i. Any serious or very serious breach of the principles set out in the Code of Conduct.

ii. Non-compliance with compliance systems implemented at local level.

iii. Acts or conduct that may have criminal implications.

iv. Serious or very serious administrative infringements.

v. Infringements of labor law in matters of health and safety at work.

vi. Infringements of European Union law included in the material scope of application of the Directive, and in the corresponding local transposition measures.

vii. Any other type of serious or very serious irregularity that may involve liability for Alter Domus.

4. What are the ways to report a violation?

Concerns may be raised by any means including, but not limited to, written (e.g. email, postal mail), verbal (e.g. phone calls, voice messaging, in person), however the concerns line is the preferred and means of communications, due to the guarantees it offers.

Concerns and irregularities can also be reported as follows:

• [email protected]: To raise queries and concern relating to the protection of personal data or the exercise of data subject rights under applicable regulation.
• [email protected]: To raise whistleblowing concerns or report suspicious transactions in accordance with the regulations on the prevention of money laundering and terrorist financing.

Local AD offices may have additional channels for raising concerns in line with local regulatory requirements.

Whistleblowers may also use public communication channels and raise acts or omissions in scope of the applicable local law and regulations with corresponding local authorities or bodies appointed to protect Whistleblowers.

5. What is the order for using the concerns line and public channels?

The concerns line is the preferred means for raising concerns. All concerns reported are subject to careful and impartial review and, where appropriate, investigation with the highest discretion, enabling timely and appropriate actions to mitigate the risk of harmful consequences.

Alter Domus encourages colleagues and contractors to raise concerns directly to their management, Compliance or HR functions unless you are not comfortable contacting us via the usual channels and your concern amounts to Whistleblowing, then the web-portal is the appropriate avenue.

6. In what timeframe and who will manage my communication?

All concerns reported are taken seriously and treated confidentially.  Alter Domus strictly prohibits any retaliation for reporting a possible violation of law, ethics or firm policy, no matter whom the report concerns.

From the notification of the acknowledgement of receipt, the assigned investigator endeavours to respond to queries and concerns raised within a maximum period of 15 days, and to complaints within a maximum period of 3 months.

Upon response the Whistleblower will be informed of the actions being carried out which will be commensurate with relevant regulations.   

7. Why should I trust that my communication will lead to action by the company to end any non-compliance or that I will not retaliate for reporting it?

The concerns line is designed to comply with applicable local law and regulations and, which are as follows:

 —- Principles and guarantees of the Internal Information System

The Internal Information System shall be governed by the following principles:

(i) Regulatory compliance: the management of concerns line shall be governed by the legislation in force.

(ii) Good Faith: The Whistleblower when reporting must always act in good faith and have reasonable grounds to presume the existence of the alleged situation of wrongdoing or malpractice. The act of making allegations that prove to be wholly unfounded, malicious, frivolous or with the foreknowledge that the allegations are false, will be viewed as a serious disciplinary offense that may result in disciplinary measures including but not limited to dismissal and administrative sanctions.

The Whistleblower is not responsible for investigating the activity nor for determining fault or corrective measures; this responsibility lies with the appropriate management staff, as described further in the Internal Information Process Description.

(iii) Absence of retaliation, protection of the Whistle-blower or other persons involved or related: provided that the communications are made in good faith and in accordance with internal regulations, Alter Domus will ensure, respect and preserve the commitment to the protection of the Whistle-blower. This includes avoiding any type of conduct aimed at applying harassing and retaliatory measures.

(iv) Independence and impartiality: Queries and complaints will always be handled fairly, with integrity, objectivity, independence and honesty. Any query or complaint submitted will be fully analyzed and resolved.

(v) Transparency and accessibility: the information relating to the Internal Information System shall be provided in a clear and easily accessible manner, with sufficient publicity regarding its use and guiding principles and guarantees.

(vi)Traceability and security: the communications sent through the Internal Information System will be registered and processed in accordance with internal regulations and with the Law, preserving at all times the integrity of the information and documentation sent, applying the necessary security measures.

(vii) Data protection and guarantee of rights: During the processing of consultation and complaint files, the measures and exercise of rights provided for in matters of data protection will be respected.

The right to information, the right of defense, the right to the presumption of innocence and the right to honor of all persons about whom a complaint is lodged and/or who are affected are guaranteed.

The accused person has the right to know the actions or omissions attributed to him/her by means of a succinct communication of the facts and to be heard at any time, in the manner deemed appropriate to ensure the successful outcome of the investigation.

(viii) Confidentiality and anonymity: Reports of alleged whistleblowing incidents of wrongdoing or malpractice and investigations pertaining thereto, shall be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation. This confidentiality shall also be ensured when the communication has been sent through non-established channels or to members not responsible for its processing.

The recipient of the communication is obliged to forward it immediately to the complaints Manager.

Disclosure of reports of alleged whistleblowing incidents to individuals without a need to know will be viewed as a serious disciplinary offense and may result in disciplinary measures and also give rise to other actions, including civil lawsuits and/or sanctions included in the local legislation.

The Internal Reporting System will allow for anonymous submissions.

(ix) Sufficiency of information: Throughout the investigation process, the instructor may request additional information and communicate with the Whistle-blower. Similarly, the person concerned shall have the right to be informed of the acts or omissions attributed to him or her, and to be heard at any time. Such communication shall take place at such time and in such manner as is deemed appropriate to ensure the proper conduct of the investigation.

For more information about the concerns framework, please contact [email protected] and the corresponding Local Integrity Concerns Manager will assist you.