This SpeakUp Policy (the “Policy”) applies to all Univers group of companies (the “Group”), so when we refer to “Univers”, “company” “we”, “us” or “our”, we mean the relevant company or companies in the Univers group.
This Policy applies to all members of Univers such as employees (full and part-time), contract workers, consultants, officers and directors of the Group (collectively referred to as "Univers Persons" or "you").
Univers reserves the right to review, revise, amend or replace the Policy, and/or to introduce new policies or guidelines to supplement this Policy from time to time to reflect the changing needs of the business and where necessary, to reflect local variations, additional requirements and/or exceptions to this Policy. It shall be every Univers Person’s responsibility to be aware of and comply with the most updated version of this Policy.
Univers is committed to responsible business practices and always conducting our businesses and operations with integrity and in an honest and ethical manner. It is essential that all Univers Persons, customers, third parties and communities in which we do business are able to report concerns about suspected or actual illegal conduct, unethical behavior or misconduct in our business.
When genuine questions and concerns are brought to our attention through our channels for speaking up, it will enable us to detect potential problems early. This helps minimize potential harm to our Univers, our customers, investors, colleagues, and business partners.
Univers is therefore determined to creating and maintaining a culture where questions can be asked and reports about unethical or illegal conduct or violations of our Code of Conduct, policies and processes, can be made via our various reporting channels without fear or threat of retaliation, and that the reports will be treated seriously, confidentially, fairly and in accordance with applicable laws and regulations. This commitment is endorsed by our top management and directors of Univers as part of their individual and collective support of our Code of Conduct.
2. GENERAL PRINCIPLES
A. WHEN TO ASK QUESTIONS OR REPORT YOUR CONCERNS
Each Univers Person has a duty to report a violation of applicable laws and regulations, our Code of Conduct, policies and associated processes, or behavior which is not in keeping with our values when such behavior occurs within our company or involves any person with whom we do business. Remaining silent in such situations may cause serious or irreparable harm to our business and/or individuals affected by such behavior.
You should also ask questions if you are uncertain about whether a particular conduct or planned course of action is legal or ethical, or if you would like guidance on the legality or ethics of a particular work-related matter.
B. WHAT MATTERS CAN YOU SPEAK UP ABOUT?
You should report concerns and/or ask for advice or guidance on actions or conduct that violate applicable laws and regulations, Univers’ values, Code of Conduct and company policies and processes. Such matters could include :-
· Financial matters such as insider trading, fraud, financial misstatements, money-laundering, terrorist funding, embezzlement, theft or cheating
· Alcohol or drug misuse
· Bribery and corruption
· Matters relating to human rights and labor law violations, including workplace discrimination, harassment (including sexual harassment), misuse of power, abuse, bullying or unfair dismissal
· Environmental and health and safety matters (e.g. if you have suffered a work-related injury)
· Conflict of interest
· Export controls and trade sanctions violations
· Misuse or breach of intellectual property and/or confidential information
· Data protection, data privacy or cybercrime
· Theft, damage to or misuse of Univers’ or a third party’s assets in our custody or control
· Product and quality concerns
· Behavior which is anti-competitive / antitrust, unfair or unethical
· Retaliation against any person who speaks up
· Forgery, falsification or improper destruction of or tampering with documents and/or information relevant to Univers or its business operations.
This Policy is not intended to deal with any questions or grievances that you may have about your terms of employment (for example, compensation, performance reviews, career development) or to settle any personal issues that you may have with your colleagues. In such instances, you should approach the HR department.
C. HOW to REPORT YOUR CONCERNS
If possible, if you have a concern about a particular conduct, do consider speaking to the person whose behavior is of concern to you e.g. if a person makes jokes that you find offensive or which make you feel uncomfortable, you could explain to the person who makes the jokes about how you feel. However, if you are uncomfortable to do so, you may use the SpeakUp reporting channels.
· your line manager;
· the HR department;
· the Legal and Compliance department; and
· the “SpeakUp” platform.
As a general guideline, the first person to approach when raising a concern internally is your line manager. However, if you do not feel comfortable or because it is your line manager that you wish to raise a concern about, you may use the other reporting channels that are available in Univers. To help you decide who to approach within Univers if you have any questions or would like to raise concerns internally, refer to the flowchart found in Annexure A.
D. misuse of REPORTING CHANNELS
When you report a concern, the information provided may result in decisions that impact others. Therefore, when making a report, you should know or reasonably believe, at the time that you makes a report, that the information provided is true. A report that is made without an honest belief about the truth of the information provided, or which is deliberately misleading, will be considered to have been made in bad faith. No protection will be afforded to you if you makes a report which is in bad faith. In fact, a report which is deliberately false or misleading will would be a misuse of the channels for reporting genuine concerns. Disciplinary action(s) may be taken against a person who misuses the channels for raising genuine concerns. However, there will not be any negative impact on you if your genuine concerns turn out to be unfounded.
2. ASKING QUESTIONS OR REPORTING CONCERNS VIA THE SPEAKUP PLATFORM
A. METHODS OF SPEAKING UP VIA THE SPEAK UP PLATFORM
The SpeakUp platform is operated by an independent service provider and is available 24/7, 365 days a year. You can ask questions or report your concerns in your own language, via phone or via the internet.
All reports and any question asked will be taken seriously.
You can ask questions or raise concerns by:-
· Web. Click on https://univers.speakup.report/compliance which is in English and choose the language you want to report in. Alternatively, you can click on the following QR Code:
· Phone. Country specific telephone numbers are found in Annexure B.
· SpeakUp app called ‘SpeakUp by People Intouch’ from the App Store/Google Play which can be downloaded onto a mobile / cell phone / mobile device. You can click on the following QR Code:-
Step-by-step instructions on how to use the different intake channels via SpeakUp are contained in Annexure B of this Policy.
B. INFORMATION TO BE PROVIDED WHEN REPORTING A CONCERN
If you wish to report a concern via the SpeakUp platform, provide as much factual information as possible. This will enable the teams that will review and/or investigate your concern to do so effectively. The types of information that you should provide include:-
· The background, history and reason for the report;
· The names, dates, places and other relevant information;
· Documents, photos, videos or voice-recordings that may support your report (possible only if the report is made online and subject to limitations in the size of the file).
You do not need to have all the facts relating to a matter of concern before making a report. It is important that you do not investigate a matter of concern to gather enough evidence to prove that a reportable violation has occurred. This should be left to the Investigation Team (defined in section 3C below). However, try to provide reasonably sufficient information to enable the Investigation Team to make at least preliminary assessments about the nature of your complaint and the individual(s) or entities involved.
C. WHAT HAPPENS AFTER YOU HAVE asked a question or raised a concern VIA THE SPEAK UP PLATFORM?
Once you have successfully submitted a concern or asked a question, the SpeakUp platform will acknowledge / confirm that your message has been received by the system.
A Triage Team (whose primary function is to conduct a preliminary high level assessment of every message received via the SpeakUp platform to determine matters such as the nature of an allegation that has been reported) will conduct an initial review of your question or report. The Triage Team will also determine the appropriate course of action and will assign the report to an appropriate person or team to answer your question, further review your concern and/or conduct an investigation (“Investigation Team”).
You will also receive a response from the Triage Team or the Investigation Team within 7 days of receiving your report.
Answering Questions, Further Review and/or Investigation
If you have asked a question that does not require any further review and/or investigation, your question will be answered as soon as possible. You may also be directed to reach out directly to the appropriate department if your matter does not fall under the scope of this Policy.
If you have made a report, the Investigation Team will determine if there is sufficient merit to your report, and may:-
· reach out to you to request for more information;
· ask if you are willing to be interviewed;
· to the extent practicable, give you an estimate of how long it will take to handle your case;
· provide you with regular updates on the progress of its investigation, to the extent that it would be legal or appropriate to do so; and/or
· propose other means to resolve the concern e.g. mediation.
The timeframes for such steps will depend on various factors such as the complexity and the nature of a case. However, the Investigation Team will proceed without unreasonable delay to address any report.
Further reviews and/or investigations will be conducted by the Investigation Team primarily through desk reviews and witness interviews may be conducted as necessary.
After completing an investigation, the Investigation Team will report its findings and recommendations to the Head of Legal and Regulatory and Compliance Counsel, which will endorse, modify or make their own recommendations on measures to be taken by the relevant Univers department(s) and/or company,
You will also be informed of the outcome of the investigation unless doing so would otherwise violate applicable law, confidentiality obligations and/or other third party rights. (It is important to remember that even a person who is accused of wrongdoing is entitled to confidentiality.)
The Investigation Team will ensure that the measures endorsed, modified or made by the Head of Legal and Regulatory and Compliance Counsel are executed by the relevant Univers department(s) and/or company.
Reporting and Closure
The Investigation Team will close the case after its investigation and recommended measures have been executed.
You will be notified once a case has been closed even if you are not informed of the outcome of an investigation.
All matters falling within the scope of this Policy that are submitted via the SpeakUp Platform will be handled in accordance with an investigation protocol.
4. PROTECTING A PERSON WHO REPORTS A CONCERN
Regardless of the channels used to report a concern internally, the following key principles are applied to anyone who reports a concern made through any of our channels for speaking up:-
Any report which you make in accordance with this Policy will be treated with strict confidentiality. Information will only be shared with a limited number of people on a need-to-know basis. Information will only be shared if required to do so by applicable law, an important public interest is at stake and/or if it is absolutely necessary in order to properly investigate the matter complained about. In principle, any person under investigation will be informed that he or she is the subject of a report being investigated as soon as possible unless the notification may jeopardize the investigation, violate applicable law or if there is a risk of retaliation against you as the person making a report.
Regardless of all measures taken to protect your confidentiality, it can never be fully guaranteed that you will never be implicated by the person under investigation. Univers also has the right to make such disclosures as may be necessary to comply with applicable laws and regulations and/or to seek independent legal advice.
Although it may be possible to report anonymously, it would be better if you disclose your identity when reporting via SpeakUp so that :-
· your concerns can be addressed more efficiently. (For example, the Investigation Team has easier access to you and ask for more details from you);
· we can provide more effective protection from retaliation as required under applicable laws and regulations (if you’re likely to suffer any); and
· any suspicion that the report has been done maliciously or in ‘bad’ faith can be avoided or minimized.
C. DATA PRIVACY
Personal data processed for the purpose of responding to reports will be processed by Univers in a transparent, fair, ethical and lawful way. Our Data Privacy and Protection Policy describes our minimum requirements for processing personal data and ensuring that we comply with applicable data protection laws and regulations.
Such personal data will be kept confidential and will only be used for the purposes described in this Policy, and/or to comply with applicable laws and regulations.
Personal data is processed in our legitimate interests to detect unethical behaviour and misconduct. In addition, personal data may be processed in order for us to comply with our obligations under applicable laws and regulations that requires us to implement whistleblowing processes and systems.
During the course of reporting a concern and/or the response to a report, personal data will be transferred across borders (i.e. outside of the country where a report is made).
When you report using the SpeakUp platform, personal data provided in the report will be hosted in the Netherlands and France. Translators who are used in relation to reports made by telephone which are not in English are located in countries with adequate levels of data protection. Personal data may also be shared with authorized employees within Univers in order to respond and handle reports made under this Policy, to monitor the reports and to have oversight of this Policy. Such transfers are subject to adequate safeguards for the protection of personal data in third countries. Where required, personal data may also be shared with third parties as may be necessary to provide support in our review and response to reports made under this Policy. These third parties have adequate technical and organizational measures and contracts have or will be put in place with them to enforce their obligations under applicable data protection laws.
If your personal data is processed in relation to a report that you make under this Policy, Univers will protect your in relation to your personal data as is accorded under applicable data privacy laws. This usually includes the right to be informed, to access, to rectify, to delete, to restrict processing, to object to and to lodge a complaint in respect of your personal data. If you do make a request about your personal data that you provide to us when you make a report or when requested by the Triage and/or Investigation Teams, your request will be reviewed on a case-by-case basis and responded to in accordance with Univers’ policies relating to data privacy and data protection.
As part of our commitment to complying with applicable laws and regulations applicable to whistleblowing and to creating a culture where all Univers Persons feel comfortable to speak up promptly about improper conduct, we do not condone and any form of retaliation, or allow any adverse action to be taken against anyone simply for asking questions, reporting their concerns in good faith and/or who co-operate with an inquiry or investigation.
Retaliation could take the form of any of the following and will not be tolerated :-
· Suspension, lay-off, dismissal or equivalent measures
· Demotion or withholding of promotion
· Transfer of duties, change of location of place of work, reduction in salary or change in working hours
· A baseless negative performance assessment or employment reference
· Imposition or administering of any disciplinary measure, reprimand or other penalty, including a financial penalty
· Coercion, intimidation, harassment or ostracism
· Discrimination, disadvantageous or unfair treatment
· Failure to convert a temporary employment contract into a permanent one, where you have a legitimate expectation that you would be offered permanent employment
· Failure to renew, or early termination of, a temporary employment contract
· Causing harm or threatening to cause harm to a person making a report, their family members, their personal property or their reputation
· Early termination or cancellation of a contract for goods or services.
If you have been threatened with or if any of the above measures have been taken against you after speaking up about your genuine /legitimate concern or after you have assisted with an inquiry or investigation, you should speak up about it.
Univers will take prompt corrective measures to deal with any instance of retaliation which is found or suspected. Retaliation or a threat of retaliation is a disciplinary matter which might lead to dismissal. Retaliation can also be a violation of applicable laws and regulations, leading to potential civil liability and criminal penalties.
It is important to note that if you have been involved in improper conduct, you may not receive the same protections set out in this Policy by making a report about improper conduct that you were involved in.
5. POLICY RELATED CONCERNS AND QUESTIONS
If you believe that a concern that you have raised under this Policy has not been properly handled, are dissatisfied with the outcome of a report, or are concerned about retaliation, ou can take the matter directly to the Legal and Compliance department..
Any questions relating to this Policy can also be made to the Legal and Compliance department.
Univers Organizational Code is:- 10365
Number: +355 4 530 1801 Call charged at local rate
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Antigua and Barbuda
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Korea, Republic of
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Freephone: 0098 0044 10266 No mobile access
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Tanzania, the United Republic of
Freephone: 0800 11 1020
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Trinidad and Tobago
Number: +1 (868) 224 1869 Call charged at local rate
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Freephone: 0080 04488 28602
Turks and Caicos Islands
Freephone: 1833 462 1355
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United Arab Emirates
Freephone: 800 0444 0408
Freephone: 080 0022 4118
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Freephone: 0004 1598 5762
Venezuela, Bolivarian Republic of
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Virgin Islands (British)
Freephone: 1833 462 1356
Virgin Islands (U.S.)
Freephone: 1833 724 6398
Freephone: +263 867 742 2010
INSTRUCTIONS ON USING THE SPEAKUP PLATFORM
Via the Web
Step 1: Have a pen and paper ready.
Step 2: Click on https://univers.speakup.report/compliance to report in English. Alternatively, you can scan the following QR code:
Step 3: To make a new report, click on the “New Report” icon. (Refer to the same image above)..
Step 4: You will be given a random report number. Write down the number as you will need it to log back in later at a later date to check the status of your report or if you want to correct or add to your report. You will also be prompted to create a password. You will need the password to log in and the report no to check on your report. (See screenshot below)
Step 5: Type your message. If you would like to include an attachment (like a photo), click on the paperclip icon on the message page (refer to screenshot below):-
Use the paperclip icon for attachments
Step 6: When you are finished, click “Send message’ in order to leave your report.
Step 7: You will be prompted whether you confirm that you wish to submit your report. If you want to review your report again, click the “cancel” button. If you are sure that want to submit your report, click “Send”.
Step 8: You will receive a confirmation of submission of your report. Don’t forgot to keep your report number as stated in the acknowledgement notice. (see sample report acknowledgement below).
Step 9: Check the status of your report after 1 week. The Triage or the Investigation Teams may need further information for you or may update you on the status of their review of your report. To do this, go back to the same URL, enter your report number and password. Although you have the option of leaving your email address, please do not do so.
Via the Phone
Step 1: Have a pen and paper ready.
Step 2: Dial the phone number for the country that you are located in. (Refer to Annexure B). Please note that most, but not all countries, have a toll-free phone number which you can call to make your report.
Step 3. The voice prompts will ask you for your ‘Organization code. Key in our Organization code: 10365.
Step 4: Select the language in which you want to leave your message.
Step 5: You will receive a random number called a ‘Report number’. Write down the Report number which you will need in order to check back on the status of your report
Step 6: You will also be asked to create a PIN Code /PIN Number. You will also need your PIN Code / PIN number to check on the status of your report or if you want to correct or add to it.
Step 7: After the tone, speak your message. Make sure to pronounce clearly, and ideally spell out any names or locations. Your message will be recorded as you will not be speaking directly to a person at the other end of the line.
Step 8 Once you have finished your message, press 1 or just hang-up.
Via the SpeakUp App
Step 1: Download the SpeakUp People Intouch’ app from the App Store/Google Play. Scan the following QR Code:-
The app looks like this: -
Step 2: Open the app to set up your PIN Code/PIN Number by clicking on “Set-Up Your Pin” .
Step 3: Enter your choice on PIN Code /PIN Number and remember it. Otherwise, you will have to uninstall and reinstall the app on your device and you will not be able to access your report.
Step 4: The App will ask you to connect to your organization by scanning the QR code. Alternatively click on “Connect Manually” at the bottom of the page and enter Univers’ organization code (103615).
Step 5: You can now make your report when you see the following screen. Press the ‘+ New report’ button.
Step 7: You can type your report or record a message. Click on “Write a message” to leave a written message or click “Record a voice message” to leave a voice message. (If you leave a voice message, it will be transcribed and Univers’ Triage and/or Investigation team will only be able to read the transcription of your voice message. They will not be able to listen to it.)
Step 8: Click on “Yes, notify me” if you want to be notified by the app of any responses. Otherwise, click “No, thank you”.
Step 9: Log out.
Step 10: Log in again to check back on the status of your report.
 Passwords must be minimum 12 characters long and must contain at least: one number, one uppercase letter, one lower case letter and one special character (!@#$%^&*)
Last modified: 13 Sep 2023