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

This whistleblowing system provides for:
  • Employees of Vivendi SE and its subsidiaries to report any breach of the anti-corruption code, in accordance with Law No. 2016-1691 of 9 December 2016 on transparency, combating corruption and modernising economic life (known as the “Sapin 2 Act”);
  • Staff members of Vivendi SE and its subsidiaries and their external and occasional personnel to report a felony or misdemeanour, a serious and obvious violation of the law or the regulations, a threat to the public interest in accordance with Law No. 2016-1691 of 9 December 2016 on transparency, combating corruption and modernising economic life (known as the “Sapin 2 Act”);
  • Members of the staff of Vivendi and its subsidiaries and their external and occasional personnel to report the existence of anti-competitive practices or violations of international economic sanctions in the activities of the group;
  • Any person to report a serious breach of human rights and fundamental freedoms (including discrimination, psychological and sexual harassment) and of the health and safety of persons and the environment resulting from the activities of Vivendi SE or its subsidiaries or the activities of their subcontractors or suppliers with whom they have an established business relationship, in accordance with Law No. 2017-399 of 27 March 2017 on the duty of care of parent companies and client companies (known as the “Duty of Care Act”).
  • Natural person: Only a natural person can submit a report via this system. Under no circumstances may it be a legal entity.
  • Personal knowledge of the facts: Whistleblowers must have been personally aware of the facts they report, i.e. they cannot infer or assume facts, act as an intermediary for anyone who refuses to make a report or merely report facts that they have not ascertained themselves.
  • Identification of the whistleblower: As a matter of principle, the use of this system is subject to identification of the whistleblower. Anonymity is only accepted in exceptional circumstances if (i) the seriousness of the reported facts is established and (ii) the facts are sufficiently detailed. Processing such a report will then require special precautions.
  • Whistleblower's behaviour: The whistleblower must act (i) in good faith, i.e. must not be motivated by an intention to harm others and (ii) disinterestedly, that is, it must not seek to obtain any financial or other advantage or satisfy any particular such as financial or non-financial interest.
Only whistleblowers who meet the above conditions may claim the protective status of whistleblower.

Note also that:
  • You can only report one fact for each report. If you wish to report several facts, you will need to submit the corresponding number of reports.
  • This is an optional procedure, which in no way replaces the conventional reporting methods such as via line management, which it supplements.
  • Misuse of this system may expose the perpetrator to disciplinary action and legal action.
The system guarantees strictly confidential treatment of any reports and protection of the whistleblower.
  • Strictly confidential framework: The system guarantees that the identity of the whistleblower, the persons referred to in the report and all the information and documents collected via the system are kept strictly confidential. Except in the case of communication to the judicial authorities:
    • Information that could identify the whistleblower may only be disclosed with his/her consent.
    • Information that could identify the person(s) in question may only be disclosed once the proper grounds for the report have been established.
  • Protective framework: Subject to submitting a report in compliance with the legal provisions and conditions set out in this section, the whistleblower enjoys a protective status:
    • The whistleblower may not be excluded from a recruitment procedure or access to an internship or training course, or be sanctioned, dismissed or subject to a direct or indirect discriminatory measure, particularly in terms of remuneration, promotion, transfer or outplacement.
    • The burden of proof is reversed for a whistleblower faced with a reprisal measure. If the whistleblower presents facts which provide grounds to assume that he/she has reported or testified in good faith, the employer is responsible for proving that any measure taken against the whistleblower is justified.
    • In the event of termination of a whistleblower’s employment contract after he/she submits a report, the whistleblower may refer the matter to the employment tribunal in summary proceedings.
    • The whistleblower cannot be held criminally liable when the information he/she discloses infringes a secret protected by law (except in the case of an infringement of secrecy in the areas of defence and medicine and of the professional confidentiality of a lawyer), provided that such disclosure is necessary and proportionate to safeguard the interests in question and that it takes place in compliance with the applicable reporting procedures.
From the date on which a report is recorded, the main contact person must carry out an analysis to determine whether or not it is admissible. This analysis is carried out on the basis of objective criteria as set out above in the “Scope of the System” and “Conditions” paragraphs.
There are two possible cases:
  • The report is inadmissible→The case is closed as inadmissible.
  • The report is admissible→The contact person in charge of the admissibility study transfers the report to contact people who are competent in relation to the nature of the facts reported. The latter then thoroughly analyse and check the reported facts in order to decide on the measures to be taken if applicable.
The whistleblower is regularly informed of the state of progress of the treatment by written notifications (except in the case of an anonymous report) and may monitor it from his/her personal area at any time.

In any event, the handling of the report is subject to appropriate precautions and measures to ensure that it is strictly confidential.

For further information on the procedure for collecting and processing reports, refer to the information leaflet on the report handling procedure for whistleblowers.
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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