The SPIE Group is committed to complying with and enforce the laws and highest ethical standards.
In accordance with the Procedure for collecting and dealing with the reports and alerts (see below), the WhistleB tool allows for the reporting of a situation which does not comply with the rules governing the Group's activities or with the ethical standards expected or which might be in breach of the applicable laws and regulations.

Who can make an alert/report?

Any member of SPIE's staff and any external or occasional worker (temporary workers; trainees; employee of a service provider or of a subcontractor, etc.) and any party involved (clients; suppliers; shareholders, etc.).

The whistleblower must:

• be a natural person;
• act in good faith; and
•  act while expecting no gain.

When you decide to report a misconduct, we encourage you to provide your identity. Anonymous alerts will only be dealt with exceptionally if the seriousness of the circumstances is established and if the facts are sufficiently detailed.

What circumstances can be reported/alerted?

The right to alert is an option that allows you to report:

• a breach of SPIE's ethical code;
• an event that might constitute a crime or an offence;
• a breach of an international commitment or of a unilateral act of an international organisation;
• a breach of a law or regulation;
• a threat to or serious prejudice to the general interest

For example:

• an internal or external fraud;
• a security risk;
• the misappropriation of assets.

What protection is implemented for the whistleblower?

The reporting channel is provided by an external service provider, the Whistleblowing Centre, to maintain the confidentiality of your identity. The reporting process is encrypted and password protected.

You will be protected against any sanction, dismissal or discriminatory measure if you have the status of whistleblower under the applicable law.

However, if you abuse this mechanism or use it in a defamatory way or in bad faith, you may be subject to disciplinary sanctions and/or legal proceedings, as appropriate.

Who receives the reports/alerts?

This external mechanism is not the only reporting channel available.

SPIE's employees or workers can exercise their right to alert:

• either by appealing to the direct or indirect line management or by referring the matter to the Compliance Officer of its subsidiary, a representative from human resources or a staff representative;
• or by appealing directly to the Group Compliance Officer Group via this secure reporting tool which guarantees the protection of personal data and strict confidentiality.

The alert will be analysed and an internal investigation may be initiated, the duration of which will depend on the complexity of the circumstances reported and the nature of the information that you have provided.

The parties involved (clients; suppliers; shareholders, etc.) exercise their right to alert:

• either via this platform;
• or by sending a letter to a person belonging to the SPIE Group.