WHISTLEBLOWING CHANNEL
For compliance with the Corporate Policy
RISO is committed to conducting its business with integrity and in accordance with the law. This commitment to ethics, standards, and responsibility is reflected in its procedural policies and in the implementation of this whistleblowing channel.
RISO encourages employees or companies with actual knowledge or reasonable suspicion of inappropriate conduct, as well as any violation of legal or regulatory requirements, to raise or report such concerns without fear of sanctions, retaliation, or unfair treatment.
RISO takes concerns about misconduct or malpractice very seriously and expects any person or company to make a report to do so in good faith. Making a report in good faith means honestly providing all known information on the subject and believing that the report is true. Reports made in bad faith or through misuse of the channel are inappropriate and constitute a violation of this policy. Such misuse can be harmful to RISO as an organization, as well as to its employees and/or external collaborators.
Complaint Procedure
- Sending a Report to the Whistleblowing Channel
If possible, please attach evidence or details that support the complaint.
Complaint Channel: Email
Details: [email protected]
1.2 Anonymity and Confidentiality
This channel is designed and managed to protect the anonymity of whistleblowers and the confidentiality of the information submitted.
Reports may be made anonymously. However, disclosing your identity is encouraged, as this allows the RISO Whistleblowing Channel team to investigate the issue further and ensure the effectiveness of the investigation. Anonymous reporting should be the exception, justified only in cases of very sensitive issues.
Neither the identity of the informant, nor confidential information disclosed in a report or during an investigation, shall be shared with anyone not designated to receive, investigate, or resolve the matter, unless:
- The reporter consents to such a disclosure.
- The disclosure is necessary to comply with state or local law (including legally mandated disclosure, such as a subpoena or court order), or with an internal policy or procedure.
- Maintaining anonymity or confidentiality would interfere with the investigation, prevention, resolution, or enforcement of discipline regarding the reported misconduct, and disclosure is limited to those with a legitimate need to know.
1.3 Reception and Investigation
All individuals filing a report are expected to have adequate knowledge of the facts on which it is based and must provide sufficient evidence of the existence of actual or suspected misconduct or behavior.
Only reports of specific allegations related to reportable matters will be responded to; general complaints or suggestions will not be investigated.
All reports submitted to the Whistleblowing Channel were initially received by the RISO Channel team (composed of members of the RKCL and RKC Legal Department). Upon receipt, the RISO Whistleblowing Channel representative will acknowledge receipt through the same channel whenever possible. Cooperation in discussing concerns is essential for proper management and resolution of the matter.
After analyzing a complaint, if the RISO Whistleblowing Channel team considers the report credible, sees that it constitutes unethical or illegal activity, and finds supporting information or evidence in the report, an investigation will be carried out. Different departments may be involved depending on their supervisory responsibilities or areas of expertise.
1.4 Retention of Reports
Information reported through the Whistleblowing Channel will be retained for as long as necessary to fulfill the purpose for which it was collected, including related legal or disciplinary proceedings. Retention periods will comply with applicable records retention and data privacy laws.
Orientation Guide
For any queries or questions about the Whistleblowing Channel, this policy, or its application, please contact:
Complaint Channel: Email
Details: [email protected]
Information to Include in the Report
Purpose: To receive and track complaints about inappropriate conduct or behavior, such as demanding or accepting bribes, questionable accounting, fraudulent financial transactions, fraud, misuse of company funds or assets, abuse of power, theft, sexual harassment, violation of company policies, and/or violations of RISO employee rights.
Objective: To establish a monitoring mechanism allowing all employees to report inappropriate conduct or legitimate concerns without fear of punishment, retaliation, or unfair treatment, and to investigate and resolve reported issues when appropriate.
Instructions: Send the report together with any supporting evidence to: [email protected]
- Consent to Disclosure: Indicate whether consent to disclosure is given:
- Consent to Disclosure: I consent to my identity being disclosed to further investigate this complaint and support the resolution of the reported issue.
- Non-Consent to Disclosure: I do not consent to disclose my identity outside of the Whistleblowing Channel team; I understand that non-disclosure may make investigation and resolution more difficult.
- Anonymous: Identity not revealed. I understand that anonymous reporting may hinder the Whistleblowing Channel team’s ability to properly investigate and address the complaint.
- Contact Information: Name, surname, company, department, email address, telephone number, and best contact hours (omit if reporting anonymously).
- Nature of Complaint: Specify whether the issue relates to fraud, theft, misuse of company assets, bribery, malpractice, sexual harassment, abuse of authority, discrimination, falsification of accounting or financial reports, leakage of data or important information, or any other inappropriate conduct.
- Details of Allegations: Provide the person(s) involved, department or office, names, dates, times, and locations. Explain how you became aware of the facts, include a chronology if applicable, and provide supporting evidence.
- Previous Reports: Indicate whether you have reported this matter to another person or organization.
- Certification: Certify that all statements made in this complaint are true, complete, and correct.
- Date and Signature: If not anonymous, include your signature and full name.