The whistleblowing system is part of the Group’s approach of ethics, compliance and Corporate and social responsibility (CSR) : by filling a report, you help the company to identify problems and resolve them.
By allowing Orange to operate in compliance with internal policies and procedures, laws and regulations, you help sustain our activity by reducing risks to our reputation and financial losses.
However, using the whistleblowing system is optional, and no disciplinary actions will be taken against any employee for not using it.
An internal alert or report filed on the Orange alert system consists in reporting or revealing certain facts, illegal or contrary to our ethical principles or to our internal policies and charters, by making them known in writing to the persons and services authorised within Orange.
Reports must relate to events occurring in the course of professional activities and must be made in accordance with the conditions described in this procedure.
Orange’s internal whistleblowing system takes charge of reports concerning conduct or situations related to Orange’s activities and which fall under the following areas:
- breaches of ethics, corruption, conflicts of interest or fraud” and in particular situations contrary to our code of ethics or to our internal policies and procedures, including our anti-corruption policy, our anti-fraud policies and our accounting, internal control and audit policies and procedures.
- any serious infringement of human rights or fundamental freedoms, the health or safety of persons or the environment,
- any situation of harassment, sexism or violence at work,
- any "other violation of laws and regulations", understood as information relating to:
•on a crime or offence (embezzlement, influence peddling, money laundering, etc.),
•a violation or attempt to conceal a violation of French law or a French regulation, European Union law or an international commitment,
•or situations relating to a threat or harm to the general interest,
•and related to Orange’ s activity.
Reports cover the fields of ethics, compliance, and social and environmental responsibility (CSR).
Good to know too
- Facts covered by national defense secrecy, patient-doctor confidentiality or lawyer-client confidentiality are excluded from the whistleblowing system.
- Likewise, the Group whistleblowing system is not intended for routine human resources matters such as queries about remuneration which should be addressed to local management teams, or customer claims which should be directed to the local customer relations teams.
A whistleblower is an employee or casual employee who reports, selflessly and in good faith, a behavior or a situation that is contrary to the items identified in the preceding paragraphs and of which they have personal knowledge, using the internal whistleblowing system.
Orange commits to ensuring that no employee is sanctioned, dismissed or subject to any direct or indirect discriminatory measures for using the whistleblowing system selflessly and in good faith for events they have personally witnessed.
Orange also commits to ensuring that procedures put in place to collect the reports guarantee that the whistleblower’s identity and the information collected through the whistleblowing system remain strictly confidential, in compliance with applicable laws and regulations.
The use of the system in good faith, even if the facts subsequently prove to be incorrect or give rise to no further action, will not expose the whistleblower to the risk of disciplinary action. However, abusing this system can lead to disciplinary sanctions for the whistleblower, as well as legal proceedings.
The Group Compliance Officer, the Group Corporate Social Responsibility Director as well as the Ethics and Compliance Officers in countries and subsidiaries concerned are responsible for guaranteeing the protection that Orange provides to employees and casual employees who report an incident via the internal whistleblowing system. They report about this mission to the Ethics and sustainable performance committee.
At least once a year, the Group Chief Compliance Officer and the Group Corporate Social Responsibility Director present the Ethics and sustainable performance committee with an anonymous report of the whistleblowing reports filed and the subsequent actions taken.
Orange encourages you to identify yourself when filing a report: it helps us to protect you, to ask you for additional information if needed, and to avoid false allegations.
An anonymous report will only be accepted and processed if it enables us to establish the seriousness of the events and if it provides enough factual details.
You can file your whistleblowing report using the internal whistleblowing system, which you can access at the following URL:
https://orange.integrityline.org
If you have chosen « Group level” or “France” as the level of processing for your report, the report will be collected and followed up by the Group Compliance Officer or an authorized member of his/her team if it is related to “corruption, conflict of interest, fraud” “breach of ethics” or “serious violations of laws and regulations”. Report will be collected and processed by the Group CSR Director or an authorized member of his/her team if it is related to serious violations of human rights and fundamental freedoms, health and safety of people or the environment,.
If you have chosen a country or a subsidiary as the level of processing for your report, it will be collected and followed up by the Compliance Officer of the country or the subsidiary concerned or an authorized member of his/her team.
You will receive an acknowledgement of receipt for your alert as soon as possible.
The person in charge of following up on the report will perform a preliminary assessment to ensure it is admissible. The preliminary assessment involves, among other things, answering the following questions:
- does the report fall within the scope of the system?
- is the content of the report based on objective information directly related to the scope of the system?
- do the facts, information or documents provided in the report support the claim?
- if the whistleblower is anonymous, is the seriousness of the facts established and are the factual elements adequately detailed?
If the report is declared admissible, it will be investigated to establish the facts. The whistleblower will be informed within seven calendar days, via the platform’s secure mailbox, about whether the report is admissible and on the opening of an investigation.
If it appears that the report does not meet one or more of the criteria described above, it will be declared inadmissible by the person responsible for following it up. This person will then inform the whistleblower and, if necessary, may suggest another, more appropriate channel: for example, customer services for sales claims, management or human resources for remuneration-related issues, etc.
If the relevance of the information appears to be inadequate, the person responsible for following it up will ask the whistleblower for further information, and if this is not available, the report may be closed without further action.
If submitted report is clearly not serious or is based on unverifiable facts, it will be closed without further action and the whistleblower will be informed of the inadmissibility.
The investigation will be conducted under the supervision of the Chief Compliance Officer or the Corporate Social Responsibility Director, or the Compliance Officer of the country or the subsidiary concerned.
The investigation team, which may belong to Group General Control, will be restricted, duly authorized and subject to an enhanced obligation of confidentiality. It will conduct the investigation rigorously and professionally in compliance with laws and regulations.
The person(s) targeted by a report that has been declared admissible will be informed of the existence of the report, strictly respecting the confidentiality of the whistleblower’s identity. Every effort will be made to avoid any prejudice to persons who are wrongly or slanderously accused by a report
At the end of the investigation, a report detailing the findings is sent to the Chief Compliance Officer or the CSR Director or the Compliance Officer of the country or subsidiary concerned who will pass it on to the relevant persons.
Depending on the findings of the report and the seriousness of the facts established, further investigation may be requested, and proportionate disciplinary measures may be taken in accordance with the internal regulations and related procedures.
If necessary, the legal authorities will take on the case. In addition, the necessary adaptations to procedures will be proposed to prevent similar behavior or incidents from occurring.
The whistleblower will be informed of the conclusion of the procedures within a reasonable time following the end of the investigation and the implementation of any ensuing disciplinary or other measures.
The data and information processed within the whistleblowing system will only be used for the purposes described in this procedure. The processing will also guarantee that the identity of the whistleblower, the identity of the person(s) accused, and the reports received remain strictly confidential. The report is processed in compliance will all applicable personal data processing rules.
Welcome to "Hello Ethics" the Orange group reporting service
You can report any conduct or situations related to the activity of Orange that violate the law or regulations (fraud, corruption, serious breach of human rights, endangerment of physical health and safety or the environment, harassment, sexism and violence at workplace etc.), and our internal policies or procedures (anti-corruption policy, code of ethics, etc.).
We would like to thank you for your cooperation.
Filing an alert or a question is done in 4 steps.
Afterwards, you can come back to consult your file on your personal secure space by the reference number of your file and a personal password.
You are now on the ‘EQS Integrity Line’ secure reporting system. This system is not part of the Orange group websites or Intranets.
This is not a customer complaints service.
This site is not intended to receive complaints related to commercial services that can not be handled by the Hello Ethics team: we suggest you contact your Orange customer service on: Orange group's websites
