Phase One requires its employees and representatives to observe and maintain the highest ethical standard of business and personal conduct of their duties and responsibilities. Employees and representatives of Phase One must practice integrity and transparency in fulfilling our responsibilities and comply with all applicable laws and regulations. Adherence to these principles will ensure our continued success and maintain the confidence of our customers and the communities in which we live.
Phase One employees and business partners are strongly encouraged to take action promptly when faced suspicions or concerns about criminal offences, violations of Phase One’s Code of Conduct and policies, and other serious violations of law or regulations that govern Phase One’s operations done by Phase One employees or third parties interacting with or working on our behalf.
Examples of areas where violations can be reported include, but are not limited to:
- Theft, embezzlement, fraud and falsifications
- Bribery and/or corruption
- Anti-trust/competition law
- Discrimination and harassment
- Major non-compliance with quality standards and procedures
- Conflict of interest
- Improper sales and marketing activities
- Violations of laws and regulations, including Phase One policies and procedures
- Major health, safety and environmental issue
- Human rights violations
- Data Privacy and IT Security
- Trade sanctions
This policy is global and applies to the entire Phase One group and associated companies, affiliates or any entity that is directly or indirectly controlled by Phase One no matter the geographical location.
The scope of the Whistleblower Hotline is suspicious or concerns about criminal offences, violations of Phase One’s Code of Conduct and policies and other serious violations of law or regulations that govern Phase One’s operations (collectively, the Compliance Standards) done by Phase One employees or third parties interacting with or working on our behalf.
The Hotline Committee is the decision-making body for the Whistleblower Hotline, except in cases where reports are made about the members of the Hotline Committee (in such cases the decision-making body is the Chairman of the Board).
The Hotline Committee consists of two members:
Chief Financial Officer, CFO
Executive Project Manager reporting to the CEO
When reporting an issue, the Reporter is strongly encouraged to provide as much detail as possible, as it will enable the Hotline Committee to conduct a thorough and accurate investigation. The more information provided to the Whistleblower Hotline, the easier it will be to initiate an investigation of the matter.
The utmost care is taken to ensure protection of the confidentiality of the Reporter and there will be no retaliation, including discriminatory or disciplinary measures, against any Reporter using the Whistleblower Hotline to report a concern in good faith.
Acting in Good Faith
Anyone filing a written complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.
How to report
Cases can be reported by filing a written report online. Reporters can report cases in English. Reports to the Whistleblower Hotline can be filed anonymously, except where prohibited by local law.