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citizenM Whistleblower Policy

In this Whistleblower Policy, you will find a step-by-step guide of citizenM's whistleblower process.

 

Introduction

citizenM Holding B.V. (“citizenM”) conducts its business based on the principles of fairness, honesty, integrity and respect. These principles have been laid down in the citizenM Rules. Accordingly, if employees notice (or suspect) a violation of the citizenM Rules, or behaviour that could likely affect the reputation or business value of citizenM in any material manner, employees[1]are encouraged to report such violation or behaviour.

In this Whistleblower Policy, you will find a step-by-step guide of citizenM’s whistleblower process. We want to reassure you that any employee should feel comfortable reporting (suspected) misconduct without the risk of retaliation. citizenM assures that all reports are handled confidentially and will be investigated promptly.

Reporting of misconduct

Employees are encouraged to report (suspected) misconduct[3] to their line manager. Employees may at all times report (suspected) misconduct to citizenM’s confidential advisor (“Confidential Advisor”). The Confidential Advisor can be contacted at confidentialadvisor@citizenm.com. Whenever a line manager receives a report of (suspected) misconduct, he or she will immediately contact the Confidential Advisor for further guidance.

For the purpose of this policy, we will not distinguish between (suspected) misconduct that is current, has already ended or is impending.

This Whistleblower Policy is not designed to cover employees’ personal grievances. citizenM has established a separate policy to resolve and redress employee grievances, which may be reported to local counsellors.

An employee may at all times consult an advisor confidentially, concerning (suspected) misconduct. This will not be seen as a breach of confidentiality by the employee.

 

Process after report

The Confdential Advisor will immediately confrm receipt of the the (suspected) misconduct report (“Report”) to the employee in writing or per email. Any report brought in good faith will receive a fair and comprehensive investigation. The Confdential Advisor will, where possible, keep the employee informed about the investigation and of the outcome and any recommendations of the investigation on a
regular basis. The employee will, where possible, be given the opportunity to respond to the outcome and  recommendations.

In certain cases, citizenM may not be at liberty to tell the employee which measures have been undertaken in response to their Report, for instance when the privacy of another employee is at stake, or because
citizenM has a duty to observe confdentiality. In those cases, the employee will be informed of citizenM’s confdentiality obligation, and the fact that they cannot be fully informed.

If a Report concerns a member of citizenM’s Board of Directors, citizenM’s CEO and the Chairman of citizenM’s Board of Directors will be informed of the Report, the outcome, and any recommendations of
the investigation, as well as the employee’s response, if any.

If the employee believes that his or her report has not received proper attention, or if the employee believes that the issue has not been dealt with in a reasonable and professional manner, they may report the issue to a regulatory authority or other relevant governmental body. If the (suspected) misconduct occurred in the Netherlands, a report can be made to the “Huis voor Klokkenluiders”. More information on how to report an issue to an authority outside citzenM can be obtained from the Confdential Advisor and from the website of the “Huis voor Klokkenluiders”. The employee may also make a report directly to a regulatory authority or other relevant governmental body, in cases where the employee reasonably believes that this is the only appropriate course of action.

 

Confidentiality

At the request of the employee, citizenM will accept and handle the report confidentially. However, citizenM cannot exclude the possibility that a report, and the results of any investigations that have been conducted in response to the report, may be handed over to a governmental body, such as the police, a prosecutor or a regulatory body.  There is also the possibility that an employee will be requested to make a formal witness statement, for instance in dismissal proceedings or following a criminal complaint.

No retaliation

An employee who reports (suspected) misconduct in good faith will not suffer any detriment as a consequence of his or her report, either in disciplinary measures, legal proceedings or otherwise. Retaliation against a reporting employee will not be tolerated and will be subject to disciplinary action.

If an employee consciously or intentionally makes a Report under the Whistleblower Policy to cause damage to a third person, he or she will be subject to disciplinary action, which may include termination of employment.

If the reporting employee is or was involved in serious misconduct, citizenM still encourages the employee to come forward, although in such a case citizenM cannot guarantee that the employee will not suffer disadvantage from (self) reported misconduct. However, citizenM does pledge to seriously consider the fact that an employee has decided to report the misconduct himself or herself.

This Whistleblower Policy will be placed on citizenM’s website.

April 2017

 

[3] For the purpose of the Whistleblower Policy, ‘employee’ refers to any person performing or having performed work within citizenM or any of its affiliated companies, either through an employment agreement or otherwise.


[2] Misconduct refers to a breach of laws and regulations, deliberate misinformation of governmental bodies, a public health, safety or environmental hazard or a risk to the proper functioning of public institutions or private enterprises.