Any matter that violates our Code of Conduct must be reported. Examples include: Financial, accounting or audit irregularities. Falsification of documents or records. Fraud or theft. Conflicts of interest. Bribery or corruption. Discrimination. Harassment. Safety or environmental hazards. Human Rights violations. Misuse of confidential information. Criminal activity Individual work-related concerns, such as scheduling, pay or co-worker issues can be reported.

Our Speak Up procedure is flexible and allows you to raise concerns about suspected misconduct through a variety of channels. You may report a Concern via the SpeakUp web application, the Ethics & Compliance Helpline or via e-mail. When using the web application or e-mail, you will receive a unique ticket number in order to be updated about the status of your report.

Yes, Speaking Up is encouraged and employees who Speak Up are protected following EU standards. Reporting suspected misconduct in good faith will not lead to any negative action against you (such as demotion, suspension, loss of benefits or harassment). Our Company does not tolerate any form of threat or retaliation against a person for raising a concern in good faith. This protection also extends to anyone giving information or cooperating in a follow-up investigation.

We encourage you to identify yourself when making a report because this will assist us with investigating the report and protecting you in the long run. Where allowed under applicable legislation, you may make an enquiry or report a concern anonymously if preferred. However, you can report a Concern anonymously via the SpeakUp web application, the Ethics & Compliance Helpline or via e-mail. If you choose to report anonymously, please ensure that you provide sufficient detail to enable the Concern to be properly investigated for example, names of individuals involved or who may be aware of the issue, times, and dates.

Our Company takes all reports of possible misconduct seriously. We will act on any legitimate formal report filed anywhere in the world. The report will undergo an initial review, and if necessary, it will be appropriately investigated. All investigations will be conducted carefully, confidentially and professionally. If it is determined that misconduct actually took place, our Company will take appropriate action.

The time to review and investigate each report varies depending upon the nature of the allegation. Some situations take longer to investigate than others. Feedback entailing the actions taken or lack thereof will be given to the whistleblower, not exceeding three months from the acknowledgement of a report’s receipt, or if no acknowledgement was sent to the reporting person, three months from the expiry of the seven-day period after the report was made.

To ensure that security is maintained for all submitted cases, if you lose your report key, you will need to file a new report. Mention in the new report that it is related to a report you previously filed.

All reporting is done in confidence, unless you allow our Company to disclose your identity. Information will only be disclosed on a need-to-know basis. Unauthorized staff members who are not explicitly referred to as recipients of reports in the SpeakUp policy will be precluded from viewing this information and your identity will not be publicly disclosed without your explicit consent. If you have asked our Company not to disclose your identity, we will not do so. The only exception is if we are required to do so by law or if an important public interest is at stake.

Speak Up is a 24-hour ethics hotline operated by an independent third party vendor, Grant Thornton, providing AVRAMAR employees, consumers, business partners and community members with a 24/7, anonymous and confidential means of reporting suspected violations of our Code.

We expect everyone to speak up and report suspected violations of Code of Conduct, our policies of law. Individuals engaging in retaliatory conduct, including threats of retaliation and attempts of retaliation, will be subject to Disciplinary Action up to and including Termination. If Reporting suspected wrongdoing helps maintain our culture of ethics. It allows AVRAMAR to address issues that could harm our reputation and prevent future occurrences of misconduct.