ESL Whistleblower Policy

What is the ESL Whistleblower system?

The ESL Whistleblower system is a confidential channel through which you can raise concerns about suspected serious violations of laws or in areas such as: insider trading, competition law, IT security, threats to health, safety and environment, theft and embezzlement, accounting manipulation, financial fraud, corruption, foreign trade controls, human rights and labour rights, workplace and/or sexual harassment, retaliation, or discrimination.

The purpose of ESL’s whistleblower scheme is to make it possible for our employees and stakeholders to make reports on occurrences in ESL without fear of negative consequences. The system thus seeks to ensure openness and transparency in relation to any (law) violations and serious misconduct.

What does the ESL Whistleblower system not cover?

The system is not for questions regarding applications for employment, commercial inquiries or disputes, ordinary HR complaints (e.g. salary, performance, vacation) or general questions. Such questions should rather be directed to the relevant Business Unit or respective functions in ESL.

Who administers the ESL Whistleblower system?

The system is administered by an independent company (Whistleblower Software) and is available 24 hours a day, seven days a week. It supports reports in over 80 languages, and you can submit a report anonymously depending on your location. The system cannot track or identify you as no cookies, IP address or similar data is stored. Meta-data is removed from files uploaded, and reports are end-to-end encrypted to ensure 100% anonymity.

Hosted on Whistleblower Software’s secure servers, the system is not a part of ESL’s website or intranet. Any report made will be kept confidential to the fullest legal extent possible.Relevant persons will be notified of and/or involved in an investigation on a "need to know" basis and/or in accordance with applicable national or international rules concerning data protection regulations.