Laudes Foundation Whistle-blower Policy

Principle statement:

Laudes is committed to act lawfully, ethically, and with integrity. We consider all violations of our Code of Ethics seriously. Any stakeholder noticing a violation of our Code of Ethics is encouraged to report those concerns so that we can address and correct them.

 

Definitions:

Whistle-blowing: the disclosure or reporting of information that relates to potential violations of the Laudes's Code of Ethics, such as: financial mis-management, bribery or corruption, discrimination or harassment, non-compliance with operational policies, procedures or controls, improper use of assets, or potential violations of applicable law, including fraud.

Whistle-blower: an individual who reports any suspected violation, as listed above. Whistle-blowers provide information based on a reasonably-held suspicion that a violation of the code of ethics or wrongdoing has occurred.

Retaliation: any direct or indirect adverse action that is threatened, recommended or taken against the whistle-blower because he or she reported a suspicion of wrongdoing.

Ombudsperson: the Ombudsperson is an independent and impartial person who is responsible for listening to employee grievances or complaints confidentially, provides them guidance on possible ways of resolving their issues, and if the employee wants to raise the matter with a complaints committee or management of the company, then the Ombudsperson ensures that the management investigates complaints in an impartial manner, attempting to resolve issues without any retaliation.

 

Key principles:

• Any stakeholder noticing behaviour or actions in violation of the Laudes’s Code of Ethics by any other stakeholders, may discuss the matter directly with that stakeholder to uncover the reason for that behaviour or action.
• If discussion with the suspicious stakeholder is not possible (e.g., there is a risk of retaliation) or the reporter does not want to have a direct discussion, the matter can be reported to the Head of Risk & Assurance, who is familiar with and committed to ensuring compliance with Laudes’s Code of Ethics and other policies.
• If none of the above is possible, or when one wants to report anonymously, the matter can be reported directly to the whistleblower@laudesfoundation.org email address, which can be accessed only by the Head of Risk & Assurance and the General Counsel.
• Ideally, violations should be reported in writing, and where possible, within six months of the event. The report should be factual and must contain specific information to assess the nature, extent and urgency of the matter.
• If the matter is very delicate or if the reporting stakeholder wishes to speak to someone in confidence, he or she may also contact one of the Laudes Ombudspersons

  • Marina Ganzarolli: +55 11 985 533 992

  • Gert Hagedoorn: +41 79 617 13 33

  • Kirthi Jayakumar: +91 96 000 74 815

• All reports of suspected or actual violations must be made in good faith. The whistle-blower must have reasonable grounds for believing that the information disclosed constitutes a potential violation.
• Reports of suspected violations will be kept confidential to the maximum extent possible, consistent with the need to conduct a proper investigation.
• The whistle-blower's identity will be kept confidential (to the extent permissible by local law) and s/he will be protected from retaliation.
• Every reported violation will be recorded in a central incident register. Depending on the nature of violation, an investigation team may be appointed by the CEO of Laudes.
• A formal investigation report of all whistle-blower incidents will be submitted to the CEO, except where reports were made against the CEO, which will be reported to the board of Laudes and the Audit and Compliance Committee.
• The whistle-blowing report (e.g. those received via email) will be acknowledged within five business days, and the whistle-blower can follow-up on the internal investigation within three months of the date of report.