PREAMBLE
Haulotte strives to combine transparency with a high level of professional ethics. Our employees are the most important source of information when it comes to revealing any misconduct that needs to be corrected.
We are therefore counting on all our employees to inform us of any behavior that runs counter to the values we uphold.
Alexandre Saubot
Chief Executive Officer
The purpose of this procedure is to provide a clear and secure framework for raising concerns and reporting potential misconduct across all countries where the Company operates.
This global policy sets out common principles applicable to all entities.
Each country may have additional legal requirements, which are detailed in the corresponding Local Annex.
This global policy sets out common principles applicable to all entities.
Each country may have additional legal requirements, which are detailed in the corresponding Local Annex.
1. Who can issue an alert?
The alert system is available to:
- Employees (permanent, temporary, part‑time)
- Former employees
- Job applicants
- External or occasional collaborators
- Contractors, subcontractors, suppliers, and service providers
- Members of management or governance bodies
Reports may be submitted by any person who becomes aware of relevant facts, regardless of how the information was obtained, provided the person believes the information is accurate.
To coordinate the receipt and processing of alerts, the Company appoints an Ethics Officer at Group level.
Mrs Caroline SIMON - Tel: +33 6 70 48 92 59 - csimon@haulotte.com & whistleblowing@haulotte.com
2. What facts can be the subject of an alert?
Any information relating to suspected or potential:
- Violations of laws or regulations applicable in the relevant country
- Violations of internal rules, charters, policies, or codes of conduct
- Fraud, corruption, bribery, competition issues, money laundering
- Accounting, financial or auditing irregularities
- Discrimination, harassment, retaliation or other workplace misconduct
- Health, safety, environmental or public protection concerns
- Data protection, privacy or information systems security incidents
- Product safety or conformity issues
- Any action that could seriously affect the Company, its employees, customers, partners, or the public interest
This list is non exhaustive.
3. Whistleblower status
Any person who raises a concern or provides information under this procedure is protected against retaliation, provided the report is made in a responsible manner and the person believes the information to be true at the time of reporting.
The following principles apply:
- No employee may be subjected to dismissal, demotion, sanction, intimidation, discrimination, harassment, or any adverse treatment because they submitted a report or participated in an investigation.
- Confidentiality will be maintained to the extent permitted by applicable local law and the needs of the investigation.
- Protection may extend to facilitators, witnesses, and individuals associated with the reporting person, in accordance with local legislation.
4. What are the safeguards for issuing an alert?
The Company takes all appropriate measures to ensure the protection and security of information collected through the alert system.
This includes:
- confidentiality of the whistleblower’s identity (when known), of the facts, and of individuals involved
- limiting access strictly to persons authorized to process the alert
- secure systems for receiving, storing, and transmitting information
Data and information are processed in accordance with the laws applicable in the country where the alert is handled and, where relevant, applicable cross border data transfer rules.
5. How to send a report
The choice is yours:
If you have any doubts or questions about a particular situation, you can choose between two alternatives:
- Internal channels
- Anonymous reporting.
INTERNAL CHANNELS
You can write and/or ask questions to:
- your supervisor, or manager
- Human Resources
- General Manager/Chairman.
- The Group's Ethics Officer directly via the following dedicated e-mail address: whistleblowing@haulotte.com
- Any designated internal contact communicated locally.
The information to be provided is as follows:
- Your surname, first name, position and place of work
You can choose to remain anonymous. However, the company's obligation to provide feedback does not apply to anonymous reporting.
- The facts you wish to communicate, in an objective and sufficiently precise manner, to allow verification of the alleged facts
- The e-mail address, if any, to which you wish to be informed of the processing of the alert, if different from the one used for the initial alert.
ANONYMOUS REPORTING
Where permitted by local law, alerts may also be submitted anonymously through the secure external reporting platform managed by service provider WhistleB.
All messages are encrypted. To ensure the anonymity of the person sending the message, WhistleB does not record IP addresses or other metadata (i.e. data that can be linked to the person sending the message). The person sending the message also remains anonymous in the subsequent dialogue with the designated Haulotte contact.
Access to messages received via our whistleblower communication channel is restricted to designated individuals with the necessary authority to manage whistleblower files. They access encrypted messages using a personal password and a secondary password. Their actions are logged, and processing is confidential.
Where necessary, individuals whose expertise may be useful may be included in the investigation procedure. These people have access to the relevant data and are also bound by a duty of confidentiality.
If a person raises a concern directly with a supervisor, manager or by contacting the alerting team in person, the message is inserted into the alerting communication channel and handled in accordance with these guidelines.
The reference person designated within Haulotte is the General Secretary of Haulotte Group, Mr. Philippe NOBLET. Should the holder of this position be called into question, the alert will be addressed to Mr. Alexandre SAUBOT.
6. How are alerts handled?
Regardless of the channel used:
Whatever the form of the alert (e-mail, post, or via WhistleB), you will receive within twenty (20) days, an acknowledgement of receipt of your alert, on the same medium as that used to launch the alert (to the e-mail address you have used or the one indicated as the chosen exchange address, or directly via WhistleB).
- Receipt of the alert will be acknowledged within twenty (20) days, except where prohibited or technically impossible (e.g., certain anonymous reports).
- An impartial investigation will be conducted by authorized persons, internally or with external experts when necessary. Individuals involved in the reported facts will not participate in the investigation.
- You will be informed of the expected timeframe within which the Ethics Officer will be able to examine the admissibility of the report.
- The Ethics Officer will carry out the necessary investigations within a reasonable timeframe, looking for evidence to prove or disprove the alleged facts. Follow up questions may be asked when needed, including via anonymous channels (where permitted).
- Appropriate corrective or disciplinary actions will be taken if the facts are confirmed.
- Once completed, the reporter will be informed of the closure of the case, subject to confidentiality requirements and local law.
7. Retention of personal data
Information collected as part of the alert system will be retained only for the time necessary to comply with:
- investigation requirements
- internal policies
- legal or regulatory obligations applicable in the relevant country
Information may be archived or anonymized in accordance with local laws and the Company’s data retention policies.
8. General information for users of the alert system
This procedure applies uniformly across all Haulotte Group companies, unless otherwise required by local law.
This procedure does not create any employment contract or guarantee and can be subject to change at any time.
The most recent version of this document is available on the Group’s internal communication channels and corporate website: haulotte.com.