What is the Sonnedix Global Integrity Reporting Channels?
The Integrity Reporting Channels, including web intake or by phone, is one of our speak-up channels to raise concerns about ethical issues and potential misconduct. It is a service Sonnedix offers for current and former employees, business partners, clients, suppliers and other stakeholders. MyComplianceReport is a web-based portal supported by an independent service provider, Ethico. It is a comprehensive and confidential reporting tool that enables everyone to address fraud, abuse, and other misconduct in our environment and to promote a healthy and safe experience for everyone.
Who operates the hotline?
Ethico, dba ComplianceLine, an independent service provider, operates the hotline 24*7 days a week.
Why do we have the Sonnedix Global Integrity Reporting Channels?
Sonnedix is committed to creating and maintaining an environment where anyone can raise concerns about ethical issues and potential misconduct without fear of retaliation. Like many global companies, Sonnedix provides the Sonnedix Global Integrity Reporting Channels as an optional service for employees to speak up.
Discuss questions and concerns with your Line Manager, Office Manager, Function Head, Representative Director, or any member of the SLT / SMT. If for some reason these contacts are unavailable, or you otherwise are uncomfortable with speaking to them directly – or feel that they have not adequately addressed your disclosure – you can use the Sonnedix Global Integrity Reporting Channels. This service provides an additional way to receive help if you feel uncomfortable asking questions or expressing concerns to management.
What is an integrity concern or ethical issues?
An integrity concern or ethical issues includes any actual or suspected breach of Sonnedix’s Code of Ethics and Business Conduct and any other improper or illegal conduct. It also includes any violation of the Sonnedix’s Code of Ethics and Business Conduct by our third parties who have committed to obeying it. A person with integrity behaves ethically and does the right thing, even behind closed doors.
The Integrity Reporting Channels does not cover employee grievances, complaints relating to job performance, or the terms and conditions of employment. These issues are not complaints that relate to potential malpractice or material misconduct, and should be channeled through the Sonnedix People team directly as they are not considered integrity concerns by nature.
What category or types of concerns should I raise?
You can raise concerns about potential violations of the Sonnedix’s global policies, our Code of Ethics and Business Conduct, the law or regulations. Some examples are concerns regarding financial wrongdoing, harassment, discrimination or other issues in the workplace, data privacy and information security, third party vendor management issues, misuse of company assets, fraud, human rights, unfair business practices, conflicts of interest, and more. Reporters are protected from retaliation for concerns raised in Good Faith (believed to be true).
Why should I report what I know?
As Sonnedix continues to achieve standards of excellence, we must be diligent and maintain high standards of integrity. In the best interest of our organization, you have an obligation to report unsafe practices, unethical behavior or violations pertaining to Sonnedix’s Code of Ethics and Business Conduct, policy or procedure, or applicable law or regulation. When someone’s actions violate our Code of Ethics and Business Conduct, our policies or procedures, or applicable laws or regulations, it can harm not only the involved parties, but our whole organization. If a law is violated, the result could be civil or criminal action against our organization and/or the person(s) responsible. We take any potential violation seriously. Reports of potential misconduct are reviewed carefully and steps are taken to correct the situation, including disciplinary action when appropriate.
Does management want me to raise my concerns?
Yes. Sonnedix requires employees to raise concerns as soon as they become aware of potential misconduct. Raising a concern can minimize the possible negative effect on Sonnedix and our people regarding financial, legal or reputational risks and health and safety threats.
Should I raise the concern first with my line manager, People or Ethics & Compliance teams?
If you are unsure whether the concern is justified and you feel comfortable contacting your management, People or Ethics & Compliance, please do so. Contact the Integrity Reporting Channels if you do not feel comfortable raising the concern with your manager or management, and People or Ethics & Compliance teams confirms that your concern could be an ethical issue or potential misconduct.
What if my manager or other managers are involved in a concern?
Reports made online, or through Ethico’s call centers, are maintained on Ethico’s secure servers. Only a select number of respective Sonnedix Ethics & Compliance team members (or People team members, if your concern is HR related) in charge of the investigation have access to reports. Ethico’s employee’s and Sonnedix’s personnel are specially trained to handle complex and sensitive matters in a confidential manner. The Ethico system and distribution protocols are designed so any individuals named in the report are not notified about or granted access to reports in which they have been named.
Can I get in trouble for using the Sonnedix Global Integrity Reporting Channels?
No. Sonnedix provides the Integrity Reporting Channels for your use and protection. Retaliation against anyone who raises an ethical concern in good faith is unacceptable. If a reporter informs Sonnedix about retaliation, Sonnedix takes this seriously and investigates. Sonnedix will discipline anyone who engages in retaliation.
I understand that any report I send from a company computer generates a server log that shows every website with which my computer connects. Will this log identify me as a report originator?
Ethico utilizes the latest in 128-bit encryption technology. No data mining or off-site web hosting is used. All of your report information is kept in their highly secured facility. Ethico does not generate or maintain any internal connection logs with IP addresses, so no information linking your computer to Ethico is available. Ethico is contractually committed to not pursuing a reporter’s identity. If you feel uncomfortable making a report on your work PC, use a PC outside our work environment (such as one located at a friend’s house, your personal PC, a public library, or internet café) through the Ethico secure website at https://www.mycompliancereport.com/MCR and inform Sonnedix company access ID: SX.
Is the Sonnedix Global Integrity Reporting Channels secure?
Yes. Your concern or question is entered directly onto the Ethico server over a secured connection. Ethico’s servers do not connect to Sonnedix’s information technology systems. Only a select number of Sonnedix Ethics & Compliance team members (or People team members, if your concern is HR related) are responsible for managing and following up on your report have access to this information.
May I remain anonymous?
Yes! As a reporter, you are NOT required to identify yourself, whether submitting your report by webform or by telephone. Providing your name and contact information is entirely optional. At the completion of the reporting process, you will be provided a report number that will allow you to follow-up on your case at a later time. Although it may be easier in many cases to address your issue by identifying yourself, you are not required to do so. If you remain anonymous, Ethico or Sonnedix will not make an effort to identify you.
Can I communicate with the investigators while remaining anonymous?
Yes. When you report a concern via the Integrity Reporting Channels, the system will provide a report number and prompt you to select a password.
Store the report number and password in a safe place. With this key, the investigators can maintain communication with you. They, or you, could ask for further information and provide feedback to you where necessary.
What does “confidentiality” mean? Is it the same as “anonymity”?
Confidentiality means that members of Sonnedix Ethics & Compliance team (or People team members, if your concern is HR related) will not disclose information to individuals outside of the reasonable “need to know” standard. This includes information received, used, maintained or accessed during the course of normal duties, such as case reviews.
Anonymity means that personnel may report any concern through the reporting channels without disclosing their identity. Reports made in good faith will be taken and reviewed without an attempt to identify the reporter.
Be advised that:
● There are circumstances in which confidentiality and anonymity may not be maintained, such as disclosures pursuant to a subpoena or court order, a lawful discovery request or a disclosure necessary to resolve a potential compliance matter.
● Anonymity applies to an individual’s identity.
● Confidentiality applies to information received, used, maintained or accessed.
● Reporters may choose to release their identity during or after a completed review.
● Information about a reporter’s identity, if provided, will be retained in the Sonnedix Ethics & Compliance department permanent records.
● Information shared outside of the Integrity Reporting Channels case review process is not protected by the Sonnedix Ethics & Compliance department.
● Information shared through the reporting channels may lead to indirect identification of a reporter given the specific details provided.
How do I use the Sonnedix Global Integrity Reporting Channels?
The Integrity Reporting Channels has two methods of intake. With Ethico, you can raise a concern in confidence by web intake or by telephone. Choose one channel, do not duplicate the report by using both channels.
Web intake portal
The first channel is the intake portal. The intake form consists of questions to identify the relevant details of your concern or question and is to understand: what happened, who are involved, where and when did it happen, and how did it happen.
The web intake portal is available 24 hours a day, seven days a week, every day of the year. You may access it from any computer that has an internet connection.
If you have documents, photos, recordings or videos, you could upload to the web intake portal.
Toll-free telephone by country
The second channel is a toll-free telephone number by country. This service is available 24 hours a day, seven days a week, every day of the year. A professionally trained Ethico operator will guide you through a series of questions to identify the relevant details of your concern or question to understand: what happened, who are involved, where and when did it happen and how did it happen.
The operator will also ask you to provide supporting documentation, if available. If you have documents, photos, recordings or videos, you could upload them to Ethico after you complete the report, and the system generates the encryption key.
At the conclusion of the call, the operator will summarize the information you have submitted and make any necessary changes to ensure that you are satisfied with the accuracy of your question or concern.
The hotline offers toll-free numbers in countries where Sonnedix operates and is available in multiple languages. Multilingual operators are available so callers can ask questions or raise concerns in their native or preferred language. You do not have to provide your name.
May I partially complete the form and return to complete it later?
No. If you close your internet browser while completing the form, the Ethico web intake portal will not save the information you have entered, so choose a time and place to use the system to complete the form.
What information do I need to provide?
The Sonnedix Ethics & Compliance and/or People teams must receive specific details concerning the matter in order to facilitate a thorough review. Providing partial or incomplete information may result in case closure due to insufficient information. Information needed to complete a thorough review may include:
● First/last name of person(s) or organization(s) engaged in alleged wrongdoing
● Description of the event, location, and date/time of when event occurred
● Specific details or synopsis of the concern(s) being raised
● First/last names of witnesses to the event or others who may have knowledge of the concern(s) being raised
● How the event was discovered if the reporter was not a participant or directly involved
● Supporting documentation if available, including policies, memoranda, emails, text messages, etc.
What should I do if the system does not list the concerned location?
Please include the actual location in the appropriate free text box field on the web form.
What happens when I ask a question?
When you ask a question, the system will direct it to the respective Sonnedix Ethics & Compliance team (or People team members, if your concern is HR related), who will respond to you through the hotline.
What happens when I raise a concern?
Whether made by web intake or telephone, all concerns are reviewed promptly by a professionally trained Ethico intake specialist. The Ethico intake specialist will send a report to the designated Sonnedix Ethics & Compliance team (or People team members, if your concern is HR related) responsible for managing and following up on your report.
The appointed team members will start the investigation if you provide sufficient details.
If necessary, Sonnedix will take appropriate remedial action while the investigation is ongoing. Those responsible for following up on your matter are trained professionals who handle the issue with discretion.
All reports, through web intake or telephone, are entered into a database for recordkeeping and case management. Only representatives within Sonnedix Ethics & Compliance team (or People team members, if your concern is HR related) have access to this information.
Do I receive confirmation of my report? What is the timeframe of confirmation?
Yes. You receive an automatic receipt confirmation that your report has been received. Right after you submit your report, Ethico’s system will automatically send you a confirmation but only if you informed any contact details. After the conclusion of the investigation, you will receive a message notifying you that the investigation has been closed. The email will indicate that all appropriate actions, if or where necessary, have been taken. You do not receive details about the investigation for confidentiality reasons.
What if I remember something important about the incident after completing the intake form?
When you raise a concern, either using the web or by telephone, the system will provide a report number and prompt you to select a password. With the report number and password, you can return to the Ethico system by Internet or telephone and access the original report. At that point, you can add more details.
How do I check a report I previously filed?
The system will provide a report number and prompt you to select a password. Record the report number and password and keep them in a safe place. Use your report number and password to re-contact Ethico to check on the status of your case, provide more information, or answer follow-up questions from those investigating the matter. To follow-up on a report you have already submitted, access https://www.mycompliancereport.com/followUp and enter your report number and password, then click ‘Proceed’. If a resolution has been provided by your company, it will be available.
If I remain anonymous, how can investigators contact me for a follow-up?
When given your report number and password, you can follow up with Ethico by telephone or web, even if you report anonymously. If an investigator wants to contact you regarding your concern, the investigator can leave you a message or ask you a question through Ethico secure website.
How long will the investigation take?
Each allegation reported is unique, so the estimated time of completion depends on many factors, such as the complexity of the issue, the number of people involved, the nature and extent of documents or other evidence involved, and the urgency of the matter.
What should I do if I lose my report number or password?
Unfortunately, if you have lost or forgotten your report number you will need to begin a new report. For security and confidentiality reasons, we are not able to retrieve lost report number’s. You can mention in the latest report that this matter relates to another report you filed earlier.