What is the purpose of this platform?
This reporting platform gives employees and stakeholders (external staff, employees of service providers or subcontractors, suppliers, shareholders and representatives of civil society) the opportunity to report any serious problem related to a breach of ethics.
These reports can be made in the event of a crime or misdemeanor, a serious and obvious violation of the law or regulations, a threat to the general interest or a breach of the code of conduct, including the existence or risk of serious violations of human rights, fundamental freedoms, health and safety of individuals and the environment.
What is a whistleblower and what are the facts they denounce?
A whistleblower is any natural person who reports or discloses, without financial consideration and in good faith, information concerning a crime, a misdemeanor, a threat or harm to the general interest, a violation or an attempt to conceal a violation of international or European Union law, the law or regulations.
As such, the facts that are the subject of the alert must be presented in an objective and factual manner, showing their presumed nature, and be directly related to the subject of the alert.
How is the anonymity of the whistleblower ensured?
It is not always easy to make a report, which is why Paragon has chosen to set up a process through a platform designed to ensure strict confidentiality, impartial and diligent treatment, protection against retaliation and compliance with national legislation.
This system is hosted by a service provider who has no access to the data but guarantees its operation.
When reporting, the whistleblower will be given the option to remain anonymous. In this case, the whistleblower will not have to give any information about his/her personal data when reporting.
The whistleblower will then be informed about the processing of the alert via an anonymous online discussion space. This area also allows for clarification and exchange with the case manager in an anonymous manner.
Please note that the information given after the declaration of the alert in order to access this space must be kept carefully by the whistleblower in a secure place.
By whom and how are the alerts processed?
The alerts launched via this platform within the framework of the PSS entity will be processed by a local referent dedicated to the category of your alert.
A group referent is also dedicated to each category of alert in order to assist the local referent if necessary.
The referents concerned by the category of an alert are indicated when the alert is declared in order to inform the initiator.
If the referent handling your alert is involved in the alert, please refer to the question "What to do if the referent of the entity is involved in the alert?
Once an alert has been registered on the platform, the referents authorised to process alerts on the platform will proceed, in complete confidentiality, to verify the facts reported, in order to determine the admissibility of the alert and to decide in full knowledge of the facts what action to take.
If necessary, they may contact the whistleblower anonymously via the discussion area in order to obtain additional information.
If the allegations contained in the alert are inaccurate or the alert has become irrelevant, the alert will be closed. In all cases, the author of the alert will be informed in writing of the closure of the file.
How long does it take to process an alert?
7 days to acknowledge receipt of the alert with written notification to the whistleblower
90 days to process and close the alert
What if the entity's referent is involved in the alert ?
If the person in charge of handling alerts in your entity is involved in the alert, you can contact the Group Ethics Officer: Patrick SAUZE - Director of Development and Strategic Projects
You can contact the Group Ethics Officer :
By mail at the following address
Patrick SAUZE - Director of Development and Strategic Projects
39 rue des Rivières Saint Agnan
58 200 COSNE SUR LOIRE
By e-mail to firstname.lastname@example.org
What if my alert concerns another Paragon entity?
You can find the links to access the other reporting platforms of the group here :
What to do if my alert is not received within 7 days after the declaration ?
In the event that a report is not received by a referent, the whistleblower may file an external report with judicial, administrative or professional authorities. The list of competent authorities is annexed to the decree (Article - Decree n° 2022-1284 of October 3, 2022 relating to the procedures for collecting and processing whistleblower reports and establishing the list of external authorities instituted by law n° 2022-401 of March 21, 2022 aimed at improving the protection of whistleblowers - Légifrance (legifrance.gouv.fr). These authorities are classified by field.
WARNING: In case of serious and imminent danger or in the presence of a risk of irreversible damage, the alert may be brought directly to the attention of the judicial, administrative or professional authorities and may be made public.
In addition, the law opens the possibility for any person to send his or her report to the Human Rights Defender in order to be directed to the appropriate body for the collection of the alert. This procedure is not part of the step-by-step alert procedure.
How our whistleblower system helps protect your privacy
- No identifying information is provided to the contacts.
- Your message will be stylometrically redacted to provide you with an even higher level of anonymity. We remove all punctuation and convert all words to lowercase."
- All information is end-to-end encrypted, so your sensitive information remains safe.
What you can do to protect yourself
- You are not on the corporate network (Internet/VPN).
- You should not use a device (smartphone, computer, etc) that is provided by your employer.
- You should not use the kinds of idioms or abbreviations that you frequently use in conversations or when writing emails.