FLAMSAL HOLDINGS LLC
AND AFFILIATED COMPANIES
This policy provides details on how you can report unethical, improper, or illegal behavior or questionable activities regarding Flamsal’s business, including where you might have concerns about an employee’s conduct with respect to the business.
It sits alongside the Flamsal Employee Policy Manual, Standards of Business Conduct, and the Employee Data Protection Notice, which are applicable to you according to the Flamsal entity that employs you. The employing Flamsal entity is the data controller of your personal information regarding your employment – please contact your local Human Resources if you have any questions about your employing entity.
When you have a concern or a question, you can:
- Talk to your local Supervisor.
- Contact your local Human Resources.
- Contact the local Legal Department.
- Contact the local Compliance Committee, if appropriate.
- Contact the Truthline.
To contact the Truthline, please visit truthline.flamsal.com.
WHAT IS THE TRUTHLINE?
The Truthline is a phone line and website that provides employees with a way to:
- Make the Company aware of any questionable activities regarding the Company’s business. Please refer to “What can be reported to the Truthline?”, below, for further information.
- Ask for guidance on any business conduct related issues.
The Truthline is available 24 hours a day, 365 days a year. The Company strictly prohibits any form of retaliation against anyone who in good faith makes a complaint or reports any suspected wrongful conduct to the Company. Reports may be made anonymously, and the confidentiality of all reports will be maintained to the extent possible.
WHAT CAN BE REPORTED TO THE TRUTHLINE?
First, the Truthline should not be used to report trivial or minor issues.
The Truthline makes it easy to report an incident about workplace issues like financial and auditing concerns, harassment, theft, substance abuse and unsafe conditions.
Human Resources and Employee Relations: Report concerns related to the way employees work with each other, their supervisors/managers, subordinate personnel, and the Company. Examples include bullying, discrimination, compensation issues, harassment, sexual harassment, medical/religious accommodations, retaliation, substance abuse, violation of social media policy, unfair labor practices, and other violations of the employee policy manual.
Ethics, Integrity and Standards of Business Conduct: Report concerns related to the violation of Company policies, laws, rules, and regulations affecting the Company’s activities and operations. Examples include bribery and kickbacks, conflicts of interest, gifts, fraud, trade compliance, money laundering, antitrust, and fair trading.
Environmental, Health, and Safety: Report concerns related to the environment, health or safety. Examples include biohazards, environmental issues, and unsanitary/unsafe working conditions.
Theft/Acts of Harm to People: Report concerns related to words or actions that threaten to inflict bodily harm to oneself or others. Examples include threats/acts of assault/violence, missing persons/welfare checks, non-employee misconduct, social media threats, stalking, suspicious behavior, or threats/acts involving weapons.
Information Security: Report concerns related to information security, unauthorized access and/or use of sensitive information, data privacy, acceptable use violations, hacking, malware, social engineering/phishing, and threat by third party services/devices.
Accounting, Auditing, and Financial Reporting Concerns: Report concerns related to the purposeful, unethical or questionable recording of financial matters. Examples may include deliberate errors related to financial statements, non-compliance with accounting controls, auditing matters, expense reporting, and falsifying financial documents.
Intellectual Property, Trademarks, and Patents: Report any concerns pertaining to the unauthorized or illegal use of the company’s intellectual property rights to include but not limited to copyrights, patents, and trade secrets.
Other: Report any concerns which do not fall into the provided list of categories. Examples may include request for guidance on Company policies, poor customer service, quality concerns, vendor concerns, etc.
If you are unsure about what you can report to the Truthline, or wish to report something not covered by the Truthline, you should speak to you Supervisor, Human Resources and/or the Legal Department as appropriate. Please note that such reports are not covered by this policy.
Abuse of the Truthline reporting system by making a report known to be false may result in disciplinary or legal action being taken against you.
HOW WILL MY INFORMATION BE USED BY THE TRUTHLINE?
We will use the information you provide to assess your concern and take action as necessary.
The details of your report will be kept confidential. However, where it is reasonably necessary and appropriate, we will share reports made to the Truthline, and the results of investigations of such reports on a need-to-know basis with other persons whose assistance is required (e.g., security department or Legal Department of your local organization or, in exceptional cases, with other affiliated companies, or outside counsel). The extent of sharing of your personal information in such circumstances will be proportionate to the need to share such information and will take into account the seriousness of the misconduct alleged and the legitimate interests of all concerned parties.
In addition to the details of your report, you are strongly encouraged to provide certain personal information, including your identity, to assist in our investigations and our compliance with law. Providing this information will enable us to investigate your concerns effectively. Where you provide your personal information as part of a report, your identity will remain confidential and will not be disclosed to persons about whose conduct a report is made, but may need to be disclosed to personnel of the organization involved in dealing with or investigating your concern, such personnel are held to the strictest confidentiality and receives special training. In certain circumstances, including where we bring formal proceedings against a perpetrator, we may be compelled by applicable laws to disclose your personal information to the perpetrator, in which case we will first ensure that such disclosure is permitted by the law and then inform you in advance of the identified disclosure. In any other case, we will disclose your personal information to a person about whose conduct a report is made only with your explicit consent.
For further information and guidance on how we process and handle your personal information, please refer to the policies linked above.
WHAT WILL HAPPEN AFTER I MAKE A REPORT?
A team member of the Truthline will open a case file and appropriate action will be initiated by the Company, in accordance with applicable laws, regulations and policies.
The Company strictly prohibits any form of retaliation against anyone who in good faith makes a complaint or reports any suspected wrongful conduct to the Company, including any disciplinary action, dismissal, transfer or change of role or refusal of promotion.
HOW LONG WILL WE RETAIN YOUR REPORT?
If you report behavior or activities that are not covered by the scope of this policy, we will immediately delete, or anonymize and archive, the information you provided.
If, after investigation, no disciplinary or judicial actions are taken, we will delete, or anonymize and archive, the information provided in your report within two months of the end of the investigation.
Where any disciplinary or judicial actions are taken, we will keep the information provided in your report until the expiration of our records retention schedule for such information.
FURTHER DETAILS
We ensure that all data processing systems (both automated and manual) used in connection with the Truthline provide for adequate technical and organizational precautions to preserve security and confidentiality of personal information and to avoid accidental or unlawful destruction or accidental loss and unauthorized disclosure to third parties, in accordance with applicable laws and regulations.
The Truthline is administered from the United States by Flamsal Truthline LLC in accordance with the instructions of your employing entity. The data will be transferred to the United States under the execution of the Flamsal Intra-Group Agreement (February 2024). The information collected within the framework of this system will be communicated solely to your employing entity, Flamsal Holdings LLC, and Flamsal Truthline LLC, the Truthline provider located in Petal, Mississippi, United States, for the purpose of managing and processing of the alerts.