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Public Interest Disclosure Policy

Last Updated: 9 August 2024

OverVIOOH

Whistle blowing means the disclosure of information by an employee, which relates to a suspected wrongdoing (e.g. danger, fraud or other illegal or unethical conduct) in the workplace.

At VIOOH, we want to ensure that we have an open and honest culture, where employees, agency staff, contractors and freelancers can feel that they can raise malpractice regarding the way we operate which may affect our employees, members of the public or our suppliers.

This might cover criminal activity, breach of legal regulations, endangering somebody’s health or safety, environmental damage and any attempt to conceal such matters. Raising concerns of this nature is making a public interest disclosure, which is often referred to as Whistleblowing. Employees who have a concern about the way they are being treated as an individual at work should follow the Grievance policy instead.

 

Public Interest Disclosure

VIOOH take all genuine concerns seriously and your concern will be treated confidentially. A public interest disclosure is a protected disclosure, which means you will not suffer any detriment if you raise concerns.

All VIOOHers have a responsibility to ensure that their colleagues are not subjected to detrimental treatment as a result of making a protected disclosure. Both VIOOH as the employer, and the person taking detrimental action, can be liable where an individual is penalised in some way for making a protected disclosure.

If you subject a colleague to any detrimental treatment because they raise a concern you will be subject to disciplinary action, which would be up to and including dismissal. For a disclosure to be protected by law it may need to fall into one or more of the below categories;

• A criminal offence has been or is likely to be committed


• A person or company has failed or is likely to fail to comply with legal obligations


• A miscarriage of justice has happened or is likely to happen


• An individual’s health and safety has been or is likely to be jeopardised


• The environment has been or is likely to be damaged

• Any information falling to any of the above categories which has been or is likely to be deliberately concealed

 

Procedure on Raising a Concern

We have ensured that there are many ways in which you can raise a public interest disclosure or if you have knowledge regarding a breach of the Code of Ethics, as well as in

the International Charter of Fundamental Social Values . Please follow one of the procedures below:

1. Your Manager, Leadership or the People Team

If you have a concern about malpractice, we hope you will feel able to raise it first with your Manager, the Leadership or People Team.

  •  Please put your concern in writing. Include as much information as you can as this will help resolve your concern quickly.

  •  If your concern is relating to your manager, then you can either raise it with the Leadership or People Team.

  •  You may then be given the opportunity to attend a meeting to discuss your concern in more detail.

  •  Where possible this meeting should take place within 10 calendar days of receiving your letter.

  •   You will be kept informed of any investigation and action taken in relation to your concern.

2. VIOOH Board

If you would like to raise a concern and do not feel comfortable sharing it within VIOOH, please put your concern in writing to the VIOOH Board (Chairman and Non-Executive Directors) via email: alert@viooh.com.


3. Confidential Reporting Systems: JCDecaux Whispli Reporting Platform:

Managed by an external service provider that is recognised on the market and is ISO 27001 certified, Whispli confirms the firm commitment of JCDecaux and its Executive Board to support the values of integrity in terms of ethics, respect for human rights, the environment and health and safety, as set out in the Ethics Charter, the International Charter of Fundamental Social Values and the JCDecaux Group Supplier Code of Conduct.


Access to the service is available to all JCDecaux Group employees and its stakeholders, in 18 languages, via https://jcdecaux.whispli.com/lp/speakup?locale=en


4. JCDecaux Group

If you have followed the steps above and would like to escalate any concerns, please contact the JCDecaux Corporate Vigilance Committee by calling 00 33 1 30 79 79 11 or via e-mail: comite.ethique@jcdecaux.fr.


If any breaches are confirmed as a result of our investigations, anyone responsible at VIOOH will be subject to our disciplinary procedure.

Please note that if the concern raised is untrue or false allegation actions may be regarded as misconduct and could be subject to disciplinary action.

Read more on the Group page:

https://www.jcdecaux.com/ethics-alert