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The use of this system and the admissibility of the report are subject to certain conditions. Please read the information below and the Whistleblower guidelines before submitting any reports.

 Scope of the system

 

  • This system is not intended to replace other existing internal (management, employee representative bodies, dedicated referents, human resources department, compliance officer) or external (e.g., the Human Rights Ombudsman) alert channels. Its use is an alternative to other alert channels, but is strongly recommended, given that the system guarantees the security and confidentiality of the processing of the alert.

 

  • The whistleblower system is available to whistleblowers who wish to report any of the following information, breaches or infringements:

 

 

Report category

 

 

 

Information, breaches or infringements

 

Whistleblower category

 

 

 

 

 

 

 

 

 

Report made under Law No. 2016-1691 of December 9, 2016, known as the 'Sapin II Law'. 

o   Conduct or situation in violation of Vivendi's anti-corruption code of conduct

 

o   Information relating to a crime or offence (including bribery)

 

o   Information about a threat or harm to general interest

 

o   Information concerning a violation or an attempt to conceal a violation of an international commitment duly ratified or approved by France, as well as a unilateral act of an international organization taken on the basis of this commitment

 

o   Information on a violation or an attempt to conceal a violation of European Union law, law or regulation (including violation of international sanctions or competition rules)

 

o   Employees of Vivendi SE and its subsidiaries, as well as external and temporary employees 

 

o   Individuals whose work contract has been terminated (provided that the information was obtained in the course of that contract)

 

o   Persons applying for employment with the relevant business unit (provided the information was obtained in connection with the application) 

 

o   Shareholders, partners and holders of voting rights in the entity's shareholders' meeting  

 

o   Members of the administrative, management or supervisory bodies 

 

o   Co-contractors of the relevant business unit, their subcontractors or, in the case of legal persons, members of the administrative, management or supervisory bodies of such co-contractors and subcontractors, as well as their staff members

 

 

Report made under Law No. 2017-399 of March 27, 2017, known as the 'Duty of Vigilance Law'

This concerns any of the following infringements relating to the activities of Vivendi SE or its subsidiaries, subcontractors or suppliers of the group:

o   Serious infringement of human rights and fundamental freedoms (including discrimination, moral and sexual harassment

o   Serious prejudice to the health and safety of individuals

o   Serious prejudice to the environment

 

 

o     Any natural or legal person

 

 Conditions
    Ø Any originator of an alert benefits from the protective status of whistleblower upon meeting the following conditions:

  • To be a natural person
  • Act in good faith: The whistleblower must not be motivated by an intention to cause harm to others.
  • Act without financial compensation: The whistleblower cannot claim to be paid for his or her alert.
  • Knowledge of facts: The whistleblower must be ' personally ' acquainted with the facts he reports but in the professional context, he may also report facts that have been communicated to him.
  • Be recognizable: The use of the system is subject to the identification of the whistleblower. As an exception, anonymity is allowed (i) if the seriousness of the facts reported is established and (ii) if the facts are sufficiently detailed. The whistleblower will only be able to benefit from the protection measures (see 'Guarantees' section) once his/her anonymity has been lifted.
    Ø Each report can address only one event. To report several events, you must create one alert for each of them.
    Ø Abusive use (e.g., making false accusations) or use of the System with bad intent can result in disciplinary action as well as legal actions being taken against the perpetrator.
  Guarantees

The system guarantees a strictly confidential treatment of any alert as well as the protection of the whistleblower.

    ØEnsuring confidentiality: The system guarantees absolute secrecy of the whistleblower’s identity, of the individuals to whom the alert is addressed including all information and documents collected through the system. Unless the alert has to be disclosed to legal authorities:

    • Any element likely to identify the whistleblower can only be disclosed with his consent.
    • Any element likely to identify the person(s) involved can only be disclosed once the validity of the alert has been established.

    Ø Protective measures: Provided the alert is issued in compliance with the provisions recalled in the “Warning” section:

    • Whistleblowers may not be subject to any form of retaliation, nor to any threats or attempts to have recourse to such measures, in particular in the forms listed in the Whistleblower Guide. (section 2.1)
    • Whistleblowers benefits from civil and criminal non-liability
      • Whistleblowers are not liable under civil law and may not be ordered to pay any compensation for damages caused by their reporting or public disclosure, provided they had reasonable grounds to believe that the reporting or public disclosure of the information was necessary to protect the interests at stake
      • Whistleblowers are not criminally liable if they infringe on a secret protected by law, provided that the disclosure is necessary and proportionate to protect the interests at stake, that it is made in compliance with the reporting procedures defined by law and that the person meets the criteria for whistleblowers set out in the law.
    • This protective status also applies to natural or legal persons who are in contact with the whistleblower:
      • Facilitators: a natural or legal person of private, not-for-profit status who assists in the reporting or disclosure e.g.: union representatives, staff representatives
      • Natural person in contact with the whistleblower e.g.: colleagues, relatives
      • Legal bodies controlled by the whistleblower for which he/she works or is connected to in a professional context
  Handling process

Ø Upon registration of the alert on the whistleblowing platform:

  • The whistleblower receives an acknowledgement of receipt within a maximum of 7 days,
  • The whistleblower is notified within a maximum of 3 months of the receipt acknowledgement of the measures being considered or taken to assess the accuracy of the allegations and, if necessary, to address the matter reported.
  • The processing time is extended to six months if specific circumstances of the alert, linked in particular to its nature or complexity, require additional investigations. The whistleblower is notified before the expiry of the initial three-month period

Ø Upon registration of the alert, the principal alert referent undertakes a review in order to assess if this alert is admissible or not. This assessment follows objective criteria listed in sections “Scope of the whistleblowing system” and “Conditions”.

  • If the alert is not receivable → The file is closed for inadmissibility
  • If the alert is admissible → The main referent transfers the alert to the competent Investigation Commisssion with regard to the nature of the facts reported, which conducts the necessary investigations and, if necessary, implements the appropriate measures.

Ø The whistleblower is notified by written notice of the progress of the processing of the alert (with exception of anonymous alerts) and can follow it at any time from his personal space.

Ø For more information on the procedure for collecting and processing alerts, please read the Whistleblower Guide.
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 Personal data protection
Vivendi SE and its subsidiaries pay particular attention to personal data protection in accordance with the applicable laws and regulations. For further information on how these data are processed via this system, please consult the relevant information note.
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Your identity

The information followed by an asterisk is required for analysis and examination of the information in your report. By providing us with your contact details, you allow us to contact you at a later date in order to obtain further details and information about your report. Remember that any information that could identify you may only be disclosed with your consent, except to the judicial authorities.
As an exception, you may wish to remain anonymous. However, in such a case your report will only be admissible if (i) it provides sufficient details and (ii) the seriousness of the reported facts is established.

Do you wish to reveal your identity?

You are submitting a report in your capacity as *
 
Title
Forename *
Surname *
In which country are you located?
To which company are you attached? *
Your job title
Telephone number
Email address *
Confirm your email address *


Do you consent to the disclosure of your personal data to third parties?
Vivendi SE, with the subsidiary to which you are attached or which is the subject of your report if applicable, is (are) responsible for processing your personal data in connection with the management and handling of your report submitted via this whistleblowing procedure. As stated above, this processing takes place in accordance with the Sapin 2 Act or the Duty of Care Act. You have the right to access, rectify and delete your data. Where appropriate, you can also ask for the processing and portability of your data to be restricted, or object to their processing, or specify guidelines on what should happen to your data after your death. For further information on the processing of your personal data and to find out how you can exercise your rights, please refer to the dedicated information notice.
* Mandatory fields
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Persons involved

To make it easier for us to handle your report, you are requested to identify all individuals allegedly involved and who could to testify to the facts you report. Remember that these persons may not under any circumstances obtain disclosure of information that could identify you.

Please identify the person(s) involved in the events you are reporting.
Person involved 1
Title
Forename *
Surname *
Telephone number
Email address
Job title
Company
The person is acting in his/her capacity as
  In accordance with Article 14 of the GDPR, the persons involved (for example as a witness, victim or alleged perpetrator) will be informed of the processing of their personal data involved in the management of the report within a reasonable time frame (no more than one month following submission of the report).
However, in the event of a proven risk of seriously jeopardising the handling of the report, this information may be deferred until the risk is eliminated. No information relating to the identity of the whistleblower or that of third parties will be disclosed, except if a disciplinary sanction or litigation is initiated following the report with regard to the person implicated, in which case the latter may obtain disclosure of this information under common law rules (the right to defence in particular).


Are there any other people involved? *



Is there a person who could testify?


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Category of facts

Select the category of facts that best describes the subject of your report. If you wish to report several facts, please create one report for each of them.

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Description of the events

Please describe the events you wish to report as objectively as possible, including the following information:
  • When and how did you become aware of the events?
  • When and where did the events take place?
The events must be described in a factual manner and a direct link to the subject of the report should be provided.
If you have any doubt about any of the facts you describe, please specify that the fact(s) is/are alleged. In addition, you are requested not to mention sensitive data (e.g. ethnic or racial origin, political opinions, religious or philosophical beliefs, trade union membership, etc.), unless this information concerns you or the implicated person and is absolutely necessary to establish the substance of your report (ex: discrimination on the grounds of ethnic origin).
If you wish to retain anonymity, please take care not to reveal your identity when writing your report, .
The description in your report should be limited to 2,000 characters. You can provide additional details by attaching documents (text file, audio, video): up to 3 files.

Are these events that: *


Precise or approximate period of the reported events *
  Start:
End:

Have you already formally reported the facts to your organisation? *


Country *

Events to which the report refers *
2000 remaining characters. If the report has more than 2,000 characters, include your report in the attached documents


Please attach any documents to support your report
  Add a document
   
 File formats: jpeg, jpg, png, pdf (Maximum size: 2MB); Up to 3 files.


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Summary of your report

Please check the information you have entered before your report is confirmed and recorded. Once your report has been confirmed, you will be able to track its handling via your personal area.

Digital footprint :
Date/Time :  


 

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