The Olky Group professional whistleblowing procedure
The Olky Group has established rules of good conduct to ensure clear and ethical governance of its activities. Since exercising the right to professional whistle blowing is an effective means of contributing to controlling the risk of non-compliance and combating corruption within the Olky Group, this system is validated by the Boards of Directors of the Olky Group companies. Its employees are also regularly made aware of the need to respect the Olky Group Code of Ethics and Conduct.
Right to professional whistleblowing
The right to professional whistleblowing is an option offered to any person who believes they have good reason to believe that a project, operation or specific situation does not comply with the rules of the Olky Group Code of Ethics and Conduct. The Olky Group's professional whistleblowing procedure is intended to facilitate the reporting of reports by Olky Group employees and by any person covered by current regulations (candidate, employee, director, shareholder or partner, subcontractor, current or former). This procedure should allow them to report, anonymously or not, information relating, for example, to a crime or an offence, a threat or harm to the general interest, a violation or an attempt to conceal a violation of applicable and binding rights (laws, regulations, etc.) or a breach of the Olky Group Code of Ethics and Conduct.
Whistleblower Protection
In accordance with the provisions of the law of 16 May 2023 transposing Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report violations of Union law (Luxembourg) and Law No. 2016-1691 of 9 December 2016 known as the SAPIN II law (France), the whistleblower benefits from a protection regime if they report or disclose information in good faith and without direct financial compensation. The whistleblower benefits in particular from protection against retaliatory measures, civil non-liability for damages that may arise from their alert and criminal non-liability in the event of concealment of confidential documents containing information related to their alert (provided their access to these documents was lawful).
This right of whistle blowing must be exercised in a responsible, non-defamatory and non-abusive manner. Misuse of the whistleblowing procedure may result in prosecution and/or sanctions. The whistle blower cannot be sanctioned if they decide not to use this right.
The Olky Group professional whistleblowing procedure is subject to the internal control system and is subject to ongoing and periodic checks.
Reporting procedure
The Olky Group provides any person concerned with the secure WhistleB platform from the publisher Navex, accessible 24/7, through which they can make a report. All information communicated is encrypted and stored in this secure and independent information system which respects all confidentiality rules. All persons involved in processing a report are subject to a confidentiality agreement and will ensure that the report is handled with the utmost care.
To report a complaint: https://report.whistleb.com/en/olky
This procedure differs from the customer complaints processing system accessible at the following link https://support.olkypay.com/client/reclamation?_locale=en