Ethics Alert

• Every employee of the JCDecaux Group, as well as every external or occasional contractor of the Group, is entitled to action this alert procedure, in accordance with the criteria and conditions set forth the law n°2016-1691 of 09/12/2016 named « Sapin II » (regarding the transparency, the fight against corruption and the modernisation of economic life).
• This alert procedure also relates to any situation of infringement of the International Charter of Fundamental Social Values of the JCDecaux Group and the principles n° 7, 8 and 9 of the United Nations Global Compact to which the group agreed in 2015, provided that such situation as well violates the applicable law or regulation in France.
• Such procedure allows to seize, depending on the nature of the subject and on the geographical provenance of the whistle-blower, firstly the immediate supervisor then, secondly, the Group's Ethics Committee.
• For the avoidance of doubt, this alert procedure is not mandatory: employees who would choose not to use it would not be exposed to any sanctions.

You are an employee of a company of the Group JCDecaux in France or in the world. You can use this alert procedure if:

• You face, in France or in any other country where the group JCDecaux has a presence, a situation contrary to the Fundamental Ethical Rules (corruption/influence peddling, free competition, financial infringements) set forth by the Code of Ethics (1) of the Group JCDecaux.
• You face, in France, a situation (2):
  • of crime or offence;
  • of clear and significant violation of an international
  • of threat or significant prejudice to the general interest.
• linked to the Group JCDecaux’s activity.

You are an external or occasional contractor (3) of a company of the group JCDecaux in France. You can use this alert procedure if:

• You are faced with, in France, a situation (2):
  • of crime or offence;
  • of clear and significant violation of an international
  • of threat or significant prejudice to the general interest.
• Linked to the Group JCDecaux’s activity.

(1)  available on the Internet website of JCDecaux on this page
(2)  law « Sapin II » n° 2016-1691 of the 09/12/2016
(3) external or occasional contractor: intermediaries, interns, consultants, services providers and employees of subcontracting companies
 

Important!

The facts, information or documents covered by national defence secret, medical secrecy and attorney-client privilege cannot be subject of a reporting in the framework of the present alert procedure.

You are an employee of a company of the Group JCDecaux in France or in the world.

• Report to your immediate supervisor, who will be in charge of guiding and advising you, and who shall transmit your request, if necessary, to the Secretariat of the Group's Ethics Committee.
• If your immediate supervisor is the author or is affected by the situation you wish to report, you may alert the Secretariat of the Group's Ethics Committee.

You are an external or occasional contractor of a company of the group JCDecaux in France.

• Report  to the Secretariat of the Group's Ethics Committee.

Note

If you don’t have the possibility to complete and send electronically and confidentially the form hereafter, you can drop your report on the voicemail provided by the Secretariat of the Group's Ethics Committee (+33 (0)1 30 79 79 11).

Specific and impartial facts

• The information submitted in the framework of this alert procedure must be submitted selflessly and in good faith, be articulated impartially and be sufficiently specific in order to be able to verify the alleged facts.
• Only the data necessary the review of the appropriateness of the alert must be submitted and the forms used to describe the nature of the facts reported must show their presumed nature.

Facts personally observed

• The facts must have been personally observed by the author of the report and are limited to the area listed in the form hereunder (see point 5).

Your identity

• You are encouraged to identify yourself while using the alert procedure.
• As an exception, an anonymous report may be processed if the facts mentioned are sufficiently serious and that the report is supported by detailed factual elements.

The elements allowing a dialogue

• You must as well provide elements allowing if need be, a dialogue with the recipient of the report.

Caution!: this alert is binding

Any person abusively using this procedure or reporting facts in bad faith, with intention to harm or knowing their untruthful nature, may be subject to disciplinary sanctions according to the Internal Rules applicable within the JCDecaux entity concerned, as well as to legal proceedings.

Recevability and processing of the report

• You will be immediately informed of the receipt of your report and with the reasonable and foreseeable delay necessary to its review, by means of a written and dated acknowledgement of receipt.  The acknowledgement of receipt does not equal recevability of the report.
• If, as employee for the group JCDecaux, you have seized your immediate supervisor, your report shall be processed by the later, who shall give it the appropriate continuation (processing, closing incident without further action or transfer to the Secretariat of the Group's Ethics, which may send it back to the Operational Management or to the Legal Department concerned for the needs of verification only and the processing of the alert.
• If you have directly seized the Secretariat of the Group’s Ethics Committee, the later will directly process your report within the framework of its responsibilities. It may send it back to your immediate supervisor and/or to the Operational Management and/or to the Legal Department in charge, for the needs of verification only and the processing of the alert.
•  The reasonable and foreseeable delay necessary to review the recevability of a report and the modalities on the possible continuation will be announced to you in a reasonable from the receipt of such report.
• If no continuation is decided, you will be informed of the closing of your file. In this case, the elements of the file of report will be destroyed or filed after having been anonymised in the applicable delays according to the local regulation.

Protection of the confidentiality of the report

• In accordance to the applicable regulation this alert procedure ensure a strict confidentiality of your identity as whistle-blower, of the identity of the persons affected by your report of the facts subject of the report and, generally, of any information provided.
• Any person having access to information within the framework of this alert procedure, its processing and the investigations that may occur, is bound by a strict obligation of confidentiality.
• Apart from the judicial authority, the elements likely to identify you as the whistle-blower cannot be disclosed without your consent. Equally, the elements likely to identify the person(s) targeted by your report cannot be disclosed before the appropriateness of the alert is set out.
• The persons disclosing confidential information may face legal proceedings and/or disciplinary sanctions.

Obstacle to a report

• Any person acting as obstacle, in any way, to the transmission of a report may face legal proceedings and/or disciplinary sanctions.

 No retaliatory measures following a report

• The Group will not impose nor tolerate any sanction, any threat, sanction, change of status, harassment, or retaliation of any kind, towards a whistle-blower of good faith in the framework of this procedure, even if the facts turn out to be inaccurate or do not go further.
• Similarly, a person cannot be rejected from a recruitment process, from accessing an internship or a professional training period, because of the initiation of an alert in the framework of this procedure. 

Data processing

• The alert procedure is implemented by JCDecaux SE in its quality of responsible of the processing
• This alert procedure implies the personal data processing which purpose is the report and the processing of the alerts issued within the framework of the present procedure and which has been authorised by the French authority in charge of the personal data protection, the C.N.I.L. (Commission Nationale de l’Informatique et des Libertés - National Commission on Informatics and Liberties). This processing is based on the respect of the legal obligations imposed to JCDecaux SE pursuant to the law
• Only the following categories of data shall be processed within the framework of the alert procedure:
  • identity, professional duties and contact details of the author of the report;
  • identity, professional duties and contact details of the persons targeted by the report;
  • identity, professional duties and contact details of the persons participating in the collect or the processing of the report;
  • facts reported;
  • elements collected within the framework of the verification of the reported facts;
  • debriefing of the operations of verification ;
  • continuation decided for the report.

Conservation period

• Any data relating to a report that will be considered as out of the scope of the whistleblowing alert procedure described below will be destroyed or filed-after having been anonymised
• When the report isn’t followed by a disciplinary or judicial procedure, the data relating to such report are destroyed or filed, having been anonymised, in a period of two months from the closing of the verification operations.
• When a disciplinary or judicial procedures is engaged against the person affected or the author of an abusive report, the data relating to the report are kept until the end of the judicial procedure.
• The archives are kept according to the applicable regulation, for a period not exceeding the duration of the contentious procedures.

Data Transfers

• In the framework of the processing of the reports, some personal data relating to the authors of the reports or to the persons targeted by these alerts can be transferred outside the European Economic Area.
• JCDecaux SE undertakes to ensure a relevant level of protection for the data transferred within this framework, in particular by generalising Standard Contractual Clauses approved by the European Commission (to which it is possible to access by sending an e-mail to: dpo_f@jcdecaux.com) or agreeing to the Privacy Shield (human resources data included) for the recipients of data located in the United-States.

Rights of individuals

• In accordance with the regulations applicable to personal data protection in most of the countries in which the Group is present and, in particular inside the European Union, any person identified in the framework of an alert procedure, whether this person is the whistle blower  or the target of the report, may contact the Secretary of the Group’s Ethic Committee in order to exert the following rights:
  • the right to be informed: you have the right to be informed concisely, transparently, clearly and in a manner easily accessible about how your personal data is processed;
  • the right of access: you have the right to obtain the confirmation that your personal data is /is not processed and, when they are, to obtain (ii) access to such data and a copy of the later ones.
  • the right to correct: you have the right to correct any inaccurate personal data about you which is inaccurate; you have the right as well to ensure that incomplete personal data is completed, by providing additional information;
  • the right to delete: in certain cases, you have the right to obtain the deletion of your personal data; however this is not an absolute right and JCDecaux may have legal or legitimate reasons to keep such data;
  • the right to limit the processing: in certain cases, you have the right to  limit the processing of your personal data;
  • the right to introduce a claim with a control authority: you have the right to the C.N.I.L. in order to introduce a claim about the practices relating to the personal data protection operated by JCDecaux ;
  • the right to give directives concerning the use of data post-death: you have the right to give directives to JCDecaux concerning the use of personal data after your-death.
• You can send your request together with the copy of an identity document to the following e-mail address hereafter:
  • comite.ethique@jcdecaux.com, or
  • you can leave a message on the voicemail dedicated of the Secretary of the Secretary of the Group's Ethics Committee (33(0)1 30 79 79 11).
• The person targeted by an alert will be  informed by the Secretary of the Group's Ethics Committee from the date of registration of data concerning this person, in order to allow this person to respond to the processing of such data. When additional measures are necessary, in particular to prevent the destruction of evidence relating to an alert, the notification to this person will occur after the implementation of such measures.
• This person may also request, under the same conditions as above, to exert his/her rights.
• JCDecaux SE has as well designated a Data Protection Representative reachable through dpo_f@jcdecaux.com.