ISS has adopted a whistleblower policy to make it possible for all employees of ISS, business partners and other stakeholders to report any serious and sensitive concerns.
In case you wish to report a serious and sensitive concern, you can report this to the Head of Group Internal Audit via a secure and externally hosted reporting site.
File a report
Follow up an existing report
In line with the ISS Values and Code of Conduct, the business integrity of ISS is non- negotiable. We are committed to conducting our business in accordance with the law and high ethical standards.
This policy aims to:
- provide a possibility for employees, business partners and other stakeholders to raise serious and sensitive concerns;
- ensure that such concerns are treated seriously and appropriately, and
- re-assure that any person raising a serious concern in good faith will be protected from reprisals or retaliation.
Employees that have a concern are encouraged to discuss such matters first with their supervisors, managers or other appropriate personnel such as local HR, local legal counsel or local CFO.
Concerns relating to the employment terms or matters at the local workplace such as conflicts with colleagues and managers, disciplinary sanctions, correct and timely payment of wages and benefits should normally be resolved locally, unless the matter is exceptionally serious as described below or cannot be reported through the normal reporting line.
This policy is meant for serious and sensitive concerns that could have an adverse impact on the operations and performance of the business of ISS, and which due to the nature of the concern cannot be reported through your normal reporting line, such as:
- unlawful activity;
- financial fraud (for example accounting manipulation, non-compliance with internal controls procedures, misappropriation of assets or fraudulent statements);
- bribery or corruption (for example conflicts of interest, bribery, sponsorships & donations, gifts or facilitation payments);
- violation of competition laws (for example price fixing, exchange of price sensitive information, collusion with competitors);
- serious endangerment to environment, health and safety;
- activities, which otherwise by law, treaty or agreement amount to serious improper conduct (for example discriminatory practises, use of child labour, human rights violations).
All communication will be anonymous and confidential unless you directly instruct otherwise. You are encouraged to identify yourself and explain your concern in sufficient detail to facilitate investigation of the matter. Follow-up questions and investigation may not be possible unless the source of the information is identified. In order to assist ISS in conducting an investigation of a complaint, please provide as much information as possible.
ISS will treat all concerns and issues raised under this policy in a confidential manner except to the extent necessary to conduct a complete and fair investigation. The identity of the complainant shall be kept confidential.
No discrimination or retaliation
ISS will ensure that there will be no discriminatory or retaliatory action against any employee or third party who reports a concern to ISS in good faith based on his/her personal knowledge. If a person believes that he or she has been retaliated against for reporting or participating in an investigation, he/she should immediately report such perceived retaliation to the Head of Group Internal Audit. All such reports will also be investigated confidentially.
Allegations made in bad faith and without any factual substance may result in disciplinary action or other appropriate reaction.
Receipt and retention of concerns and investigation
Each complaint or concern will be received by the Head of Group Internal Audit. The Head of Group Internal Audit shall (i) record all reported complaints or concerns, (ii) consider the seriousness and credibility of the complaint or concern raised and (iii) proceed accordingly in determining the appropriate action. Some complaints or concerns may be resolved without requiring investigation.
The Head of Group Internal Audit may, in his/her sole discretion, consult with the Audit Committee (or a body appointed by the Audit Committee) and any senior members of the management. He or she may also engage external auditors, investigators and/or legal counsel to assist in the investigation and analysis of the results thereof.
The conclusions of the investigation shall be submitted to the Audit Committee. The Audit Committee may decide on placing any investigation report before the Board of Directors depending on the gravity and magnitude of the violation.
In case an investigation shows any violation of this policy, appropriate remedial action will be taken.
Retention of the Records
ISS shall retain a copy of all complaints or concerns, investigation reports and all relevant documentation thereof. The Audit Committee shall decide the period of retention of all these records by ISS, subject to limitations in applicable legislation.