Employee Whistleblowing Procedure
What types of concerns are covered by this Policy?
This Policy covers situations where an individual (both external and internal to Mazars) raises a concern about a risk, malpractice or wrongdoing that affects members of the firm, in the following areas:
- Financial, accounting,
- Bribery and corruption,
- Antitrust practises,
- Danger to health and safety,
- Danger to the environment,
- Discrimination and harassment.
These concerns are referred to here as “Malpractice”. This Policy does not cover concerns or complaints about your own personal employment position. Any such concerns or complaints should be raised through the firm’s grievance procedure. This Policy does not either concern risk, malpractice or wrongdoing in any other area than those listed in the present section and/or that affect persons that are not members of the firm, such as clients, suppliers...
Protection under this Policy
The whistleblowing procedure is facultative and Mazars employee liability shall never be triggered for not having raised a whistleblowing alert.
You are not required to prove any matters raised under this Policy. An honest and reasonable suspicion that malpractice has been or is likely to be committed is sufficient.
Subject to the provisions of Section “Personal Liability”, if a Mazars employee raises a concern under this Policy, you will not be at risk of losing your job or suffering any form of retribution as a result. Provided you are acting honestly and reasonably, it does not matter if you are mistaken about your concern.
Mazars will not tolerate the victimisation or harassment of staff that have raised a concern under this Policy. All allegations of such treatment will be taken seriously and if well founded will usually be investigated under the firm’s disciplinary procedure as potential gross misconduct. Anyone found to have treated a colleague in this way may be dismissed without notice or pay in lieu of notice.
Personal Liability
Maliciously making a false allegation under this Policy constitutes gross misconduct and is likely to trigger disciplinary sanctions and/or legal prosecution.
What to do if you have a concern
If you have any concerns about Malpractice, you can raise it through the Form below (Data cannot be accessed by local teams and Form cannot be altered by local teams).
The Mazars Group Chief Compliance Officer[1] will liaise with the Group Governance Council or its Independent Members only and, to the extent needed, to the Group Executive Board. In any case, please note that members in charge of receiving and dealing with whistleblowing alerts are subject to confidentiality undertakings.
It is important that a team member feels able to report concerns without fear of reprisal. Therefore, allegations of victimisation in such situations will be taken very seriously and disciplinary action taken against any personnel found guilty of such behaviour.
Confidentiality
Any concern raised under this Policy will remain confidential between the person who raises the concern, the Mazars Group Chief Compliance Officer and, to the extent needed, any other member who would have communication of the alert. Thus, any information you provide under this procedure will also remain confidential, including your identity.
In this respect, please note that concerns cannot be raised anonymously and you shall provide information on your identity, which will always remain confidential and shall never be communicated to the member who is the subject of the alert.
Depending on the nature of the matter you have raised, the firm may be required by law to disclose some or all of the information to a third party. You will be informed if such disclosures are made.
Whilst investigating the matter, the Group Compliance Officer may require you to provide further information. Your co-operation after you have raised a matter is essential for the proper investigation of your concern.
Once the matter has been investigated, you will be provided with a report of the findings. If you have raised a concern which proves to be well founded, the findings of the investigation will also be reported to the relevant Management Unit Leader who will take appropriate action.
The making of malicious allegations regarding a Mazars firm’s activities to external persons will constitute gross misconduct and will be investigated under the firm’s disciplinary procedure. Anyone found to have made a malicious allegation may be dismissed without notice or pay in lieu of notice.
Record Keeping
A central record of all alerts will be held by the Mazars Group Compliance Officer, who will report on the outcome of investigations to the National Executive and to the firm’s Independent Non-Executives.
Alerts that do not fall into the scope of this Policy will be shortly destroyed or recorded in a separate system. Those that fall into the scope of this Policy but do not result in disciplinary or judicial proceedings will not be kept more than 2 months after the investigation are closed. Those that result in disciplinary or judicial proceedings will be kept until the termination of the proceedings.
Mazars uses all appropriate security measures to ensure the protection of the information collected in the context of this Policy, in compliance with this Privacy Policy and with all applicable regulations.
Right of access and modification
You have a right of access, opposition and correction of data that concern you and to ask for their modification or deletion if they are incorrect, incomplete or obsolete, in accordance with the applicable data protection regulations. To exercise such right, please use the Employee Contact Form below.
As of January 2018, the Group Chief Compliance Officier is Jean-Luc Barlet.