CONCERN REPORTING CHANNEL

How it works

Step 1

Complete Your Report

Begin your report, attach any necessary files, and save a draft if you’d like to finish later. Submit your completed report when you’re ready.

Step 2

Chat Safely

After submitting your report, you can start a chat with Constell Group, even if you chose to remain anonymous.

Why should I submit a report?

Every employee is responsible for ensuring compliance with applicable laws, the Group’s Code of Conduct, and internal policies.

While we encourage reporting ethical concerns through normal channels, the Constell Compliance Line provides an alternative for reporting misconduct or violations that cannot be raised through usual means.

Submitting a report helps Constell Group enhance its policies and reduce potential harm to people and property.

What kinds of reports can I submit?

The Constell Compliance Line allows employees and external stakeholders to report, in good faith, violations of laws, regulations, or the Group’s Code of Conduct.

You will be asked to choose one of the following categories when reporting:

• Anti-competitive practices
• Conflict of interest
• Corruption and influence peddling
• Discrimination
• Fraud / Books and records falsification / Misappropriation of assets
• Harassment
• Money laundering
• Other human resources issues
• Privacy breach
• Retaliation connected to a previous alert
• Violations of environmental laws
• Violation of human rights
• Violations of health and safety regulations
• Violations of other ethical principles of the Constell Group Code of Conduct

The Constell Compliance Line should not be used for routine HR matters, such as remuneration and performance. These issues should be directed to your manager and HR management. Only reports that fall within the specified scope will be addressed through the Constell Compliance Line.

Additionally, please note that the Constell Compliance Line cannot receive or address reports that involve matters of national defense secrecy, medical secrecy, or attorney-client privilege.

Please ensure that your report is as objective and detailed as possible, and include any supporting evidence that you may have. If you are unsure of some of the facts in your report, please specify.

How is the confidentiality of my report ensured?

Your identity remains confidential and will only be disclosed to authorities if legally required. The accused will be informed of allegations and case closure. They may access and correct their personal data.

PURPOSE & SCOPE OF THIS POLICY 

The Constell Compliance Line allows Constell Group employees and external stakeholders to submit good faith reports of a criminal offense, violation of applicable law, or threat to the general interest; and/or violations of the Group’s Code of Conduct and internal policies.

Constell Group will be the primary recipient of the report and in charge of investigating the reported facts.

Constell Group will access personal data regarding the user and the persons named in the Report.

This privacy policy describes the terms and conditions under which Constell Group may collect and process personal data and applies to all users.

TYPE OF PERSONAL DATA COLLECTED & PROCESSED 

Constell Group will collect and process personal data about users who submit reports via the Constell Compliance Line and the reported data subjects to the extent necessary for handling the report. 

Only include personal data essential to the report.

PURPOSE OF DATA COLLECTION & PROCESSING 

Constell Group will use personal data to manage the report, investigate the reported facts, launch any necessary claims or disciplinary procedures, enforce any applicable remediation measures and/or sanctions, and report the facts to judicial or governmental entities or in response to court orders, legal procedures, or subpoena.

RECIPIENTS OF THE DATA 

Reports submitted via the Constell Compliance Line will be reviewed by a select group of examiners who are obligated to maintain confidentiality. 

For investigation purposes, examiners may share reported information, including personal data, with relevant parties within Constell Group. All information will be treated confidentially and shared only with necessary persons. 

User identity will not be disclosed without express approval, except to competent authorities