ʺThales Alert Linesʺ platform

Thales is committed to respecting the laws and ethical principles that regulate its activities.

Thales has set up a "Thales Alert Lines" alert platform to report (i) any conduct or situation that does not comply with the Group's internal rules or with applicable laws and regulations or (ii) the existence of risks or serious violations to human rights and fundamental freedoms, the health and safety of persons as well as the environment resulting from the activities of the Group and its sub-groups or suppliers with whom an established business relationship is maintained, where such activities are related to that relationship.

The Thales Alert Lines platform is intended to receive reports concerning any of the conduct or situations listed below, transmitted by an individual acting in good faith. This includes, for instance and not limited to, internal or external employees, occasional employees of the Group (temporary or contractor), a third party individuals (such as an employees but not limited to) of a customer or supplier of the Group. 

Please note that if the person reporting is an employee, depending on his or her preference and the circumstances, he or she may also choose to report via the hierarchical channel or the referent related to activities linked to the issue raised in the report under the conditions provided for in the Group’s internal instruction.

The Alert Platform is available under the Thales Alert Lines. 

It allows alerts to be issued 24 hours a day, 7 days a week, via a form available in seven languages (Dutch, English, French, German, Italian, Portuguese and Spanish).

A report may concern (i) any conduct or situation that contravenes the Thales Code of Ethics or Code of Conduct 'Prevention of Corruption and Influence Peddling', (ii) any other violation of laws and regulations or (iii) the existence of risks or serious infringements to human rights and fundamental freedoms, the health and safety of persons as well as the environment resulting from the activities of the Group and its sub-groups or suppliers with whom a business relationship is maintained, where these agents are connected to this relationship, in particular in the following areas:

• Money laundering, financial and accounting offences
• Conflicts of interest
• Compliance with trade rules
• Fraud
• Harassment/Discrimination/Violence in the Workplace
• Anti-competitive practices
• Environmental issues
• Issues related to the protection of personal data
• Health and safety of persons
• Product safety
• Information security and protection
• Violation of Human Rights and Fundamental Freedoms (*)

(*)  Violation of Human Rights (forced labour, child labour...)  and Fundamental Freedoms (freedom of association, right to collective bargaining).

When the author of the alert transmits a report via the Alert Platform, he/she is asked to fill in an electronic form, including the country where the events leading to the report occurred, the nature of the alert and his/her identity (if he/she agrees to identify himself/herself). 

Once the form has been filled in and submitted, the Alert Platform automatically generates a unique identification code, which, together with the password that the author of the alert has chosen, gives him/her access to a platform allowing him/her to exchange information and secure documents with the people in charge of collecting and processing the alert. 

This identification code and password also enable the author of the alert to access the information provided to him/her and to answer any questions sent to him/her via the Alert Platform in relation to his/her report and to provide additional information.

Important:
In order to access the exchange section of the Alert Platform, the author of the alert must carefully keep this unique identification code as well as the password that he/she has chosen. Otherwise, he/she will no longer be able to access the alert submitted and will have to renew his report.

The Alert Platform allows anonymous reporting. 

Thanks to the exchange platform dedicated to the filed report, the Alert Platform allows for further exchanges with the author of the alert while allowing him/her to remain anonymous if he/she so wishes. 

Within a maximum of 15 calendar days from the date of receipt, an Alert Monitoring Committee assess whether the transmitted alert is actionable or not. 

If the alert is not declared actionable, the author of the alert will be informed of the reasons why the alert was not declared actionable and his or her alert will then be immediately destroyed. 

If the alert is declared actionable, the author of the alert is, as far as possible, informed of the follow-up given to the alert. 

The author of the alert benefits from the protections provided by the applicable regulations.

Thales also commits not to punish, dismiss or discriminate against any employee because of a report made in good faith and concerning facts falling within the scope of the internal alert system.
 

Thales respects the confidentiality of the identity of the author of the report, of the person(s) involved and of the information gathered by any person responsible for collecting or processing the alerts.

Personal data is collected and processed by Thales and the legal entity of the Thales Group in the country where the incident occurred, acting jointly as data controller, in order to communicate with the person reporting the incident for better management of the alert. The author of the alert has the right to access, rectify and delete his or her data, as well as the right to object to the processing and to its limitation. 

When submitting a report, the author of the alert is provided with detailed information on the use of personal data.

The author of the alert may also contact the Group's Data Protection Officer by sending an e-mail to the following address: dataprotection@thalesgroup.com.