INTERNAL ALERT COLLECTION AND PROCESSING PROCEDURE

Preamble

As part of the whistleblower protection defined by law n°2016-1691 of December 9, 2016, modified by law n°2022-401 of March 21, 2022, CLAREO has defined an internal procedure for collecting and processing reports issued by whistleblowers, taking into account the requirements of decree n°2022-1284 of October 3, 2022.

This procedure is applicable from June 26, 2025.

This system complements traditional reporting channels and its use is simply optional for employees and collaborators.

1. Purpose and Scope

This internal procedure for collecting and processing alerts aims to promote and regulate the reporting of facts that may constitute:

a crime or offense;
a serious and manifest violation of law or regulation;
a violation or attempted concealment of a violation of an international commitment regularly ratified or approved by France, or a unilateral act of an international organization taken on the basis of such commitment;
a threat or harm to the public interest.

The report cannot concern elements covered by national defense secrecy, medical confidentiality, or attorney-client privilege.

2. Definition of Whistleblower

A whistleblower is a natural person who reports, in a disinterested manner, in good faith and without malicious intent, facts of which they have personal knowledge, and which may fall under the qualifications listed in Article 1 above.

Can be whistleblowers:

Company employees, former employees or job candidates;
Shareholders, partners and holders of voting rights in the general assembly;
The managers;
External or occasional collaborators;
The company's contractors, subcontractors or, in the case of legal entities, members of staff and of the administrative, management or supervisory body of a contractor or subcontractor.

3. Reporting Channel

Reports can be made through the following means:

Dedicated email address: [email protected]
Depending on the nature of the breach, your report will be handled either by Vincent FOURNIER (Chief Executive Officer) or by Maud PANIS (Human Resources Director), according to their respective competencies.
You may also request a direct interview (by appointment) with one of the 2 representatives mentioned above.

Reports received by other persons or departments must be transmitted to one of the Whistleblower Representatives without delay.

In case of a report made during an interview with a Whistleblower Representative, the report is transcribed in writing by the recipient, who establishes precise minutes of the conversation.

The whistleblower has the possibility to verify, correct and approve the minutes by affixing their signature.

The minutes can only be kept for the time strictly necessary and proportionate to the processing of the report and the protection of its authors, the persons they concern, and the third parties they mention.

4. Report Content

The whistleblower is invited, when possible, to:

indicate the date of the reported facts, location, person(s) involved, and a detailed description of the facts;
provide any evidence, regardless of its form or medium, supporting the report of facts mentioned in Article 1, which have occurred or are very likely to occur in the company;
provide contact details to allow communication with the alert recipient (email address, phone number, postal address, etc.).

Information communicated within an alert system must remain factual and have a direct connection with the subject of the alert.

The whistleblower submits along with their report any evidence proving they belong to one of the categories of persons mentioned in Article 2.

5. Acknowledgment of Receipt

The whistleblower will receive written acknowledgment of receipt within 7 working days following the receipt of their alert.

6. Examination of Admissibility and Report Processing

Each report undergoes a preliminary examination to verify the admissibility of the alert, according to the conditions defined in articles 1 and 2.

In particular, the alert must fall within the scope of the alert system, be presented objectively, without malice, and concern facts directly observed by the whistleblower and materially verifiable. For this purpose, any additional information may be requested from the whistleblower.

The whistleblower is informed of the admissibility or inadmissibility of their alert and the reasons why it is deemed, if applicable, that their report does not meet the alert admissibility conditions.

The processing of the report is handled by the Whistleblower Representative, in collaboration with the legal department and management if necessary. It is based on the following principles:

Confidentiality: The identity of the whistleblower, the persons concerned, and mentioned third parties is strictly protected. Only persons authorized to collect and process reports may access the collected information. They may be communicated to third parties provided this communication is necessary to process the report.
Information regarding the whistleblower's identity can only be shared with third parties with their consent. However, it may be communicated to judicial authorities in cases where persons responsible for collecting or processing reports are required to report the facts to them. The whistleblower is then informed, unless this information risks compromising the judicial procedure.
In all cases, the identity of the report's author is never communicated to a person subject to this report, except with the author's express agreement.
Elements that could identify a person subject to a report may only be disclosed, except to judicial authorities, once the validity of the alert has been established.
Impartiality and Objectivity: The report is analyzed neutrally. The accuracy of all recorded elements is verified. Additional information may be requested from the whistleblower.
Management of Anonymous Reports: in principle, anonymous alerts are inadmissible and cannot be processed, unless the severity of the mentioned facts is established and the factual elements are sufficiently detailed, and only after a preliminary examination by the alert recipient to decide on the appropriate follow-up.

7. Informing the Whistleblower of the Report's Follow-up

The company has 3 months from the acknowledgment of receipt of the report to investigate and inform the whistleblower of the measures taken or the closure of the investigation.

When the report is closed, due to inaccurate or unfounded allegations, or if the report has become irrelevant, the whistleblower is informed in writing of the case closure.

8. Whistleblower Protection

Pursuant to Article L. 1121-2 of the Labor Code, no retaliatory measures, direct or indirect (sanction, dismissal, intimidation, etc.), may be taken against a whistleblower who has reported facts in good faith.

In case of disclosure of a legally protected secret, provided that this disclosure is necessary and proportionate to safeguarding the interests at stake, that it occurs in compliance with the reporting conditions defined by law, and that the person meets the whistleblower definition criteria, the latter is not criminally liable (Criminal Code art. 122-9).

Disclosure of the whistleblower's identity without their consent is punishable by 2 years imprisonment and a 15,000 euro fine (law n°2016-1691 of December 9, 2016, art. 9).

Any person obstructing the transmission of an alert, in any way, is liable to 1 year imprisonment and a 15,000 euro fine (law n°2016-1691 of December 9, 2016, art. 13, I).

9. Information of the Person Subject to an Alert

Any person subject to an alert is informed by the person responsible for processing:

of the facts alleged against them in order to exercise their defense rights;
of the procedures for exercising their rights to access their personal data and rectify it.

This information is provided in ways that ensure its proper delivery to the person concerned. It does not contain information about the identity of the alert sender or third parties. This information must be provided within a reasonable timeframe not exceeding one month.

However, it may be delayed when it is likely to seriously compromise the investigation needs, in the presence of a risk of evidence destruction.

10. Procedure Distribution

This procedure is accessible on CLAREO's website.

Done in Paris on 25/06/2025

Vincent FOUNIER, Chief Executive Officer