Since 2013, our code of conduct has described the central principles of our corporate culture. It was updated in autumn 2020 so that we can continue to meet the increased number of ethical and regulatory requirements presented by our fast-moving world. The code of conduct will therefore continue to guide our decisions and help us to prevent any misconduct. The new and additional content is based on common international standards and requirements.
The code of conduct is binding upon all employees at all CHG-MERIDIAN locations. It also sets out our expectations for how our customers, suppliers, and other business partners should behave. Acting with integrity at all levels creates trust both internally and externally and is essential to our continued commercial success.
CHG-MERIDIAN expects its employees and business partners to report attempted, suspected or actual compliance violations. Contact persons for such reports include immediate supervisors, senior management, the Group Regulatory Officer as well as an external ombudsman.
Our behavior towards one another is characterized by respect, trust, and tolerance. We therefore handle all reports of possible violations as strictly confidential. We assume that our whistle-blower system will be used responsibly and with integrity.
A report will not be classified as a breach of confidence. Such reports will not result in discriminatory action against the reporting person, provided that he or she made the report in good faith regarding the accuracy of his or her statements. The whistle-blower remains anonymous at all times unless the whistle-blower expressly permits disclosure either in advance or after the fact.
The CHG-MERIDIAN ombudsman is - in addition to the Group Regulatory Officer - the central point of contact and the anonymous authority with respect to CHG-MERIDIAN in the whistle-blower system.
Non-disclosure agreement between CHG-MERIDIAN and the ombudsman:
1. Does CHG-MERIDIAN have a group wide whistleblower reporting channel?
Yes. CHG-MERIDIAN provides group wide channels. Some of the channels are public, transparent, barrier-free and anonym. All reports are treated equally.
2. Who can report?
Everyone as it is available for all persons. For employees as well as external third parties and stakeholders.
3. What can I report?
Every suspicious activity of real, attempted or suspected violation and breaches of laws and internal rules. This includes also suspected fraud attempts. Concerns can be reported against internal employees as well as processes related to CHG-MERIDIAN business and business partners.
Please only report if you believe the violation or breach to be true. Please do not report business related complaints or inquiries. E.g. Request for Proposal (RFP) or Request for Information (RFI) or TESMA technical complaints.
4. Do I have different ways to report?
Yes. CHG-MERIDIAN provides different channels. You can contact your manager, Regulatory Affairs individually or via the Regulatory Affairs Portal. You can also use the external Ombudsman.
5. Who is responsible processing my report?
The report is usually processed as an security incident within Regulatory Affairs. Additional local Officers or Managers might be involved if necessary following a strict confidentially approach.
6. Is my identity treated confidentially?
Yes. Beside data protection requirements, all reports and security incidents are treated confidentially. If you want to stay anonym you can contact the Ombudsman.
7. Will I be notified regarding the status of my report?
Yes. If you use internal channels you have direct contact with Regulatory Affairs anyway. If you contact the Ombudsman you will receive a confirmation within 7 days and a status update within 3 months if it is technically possible.
8. Will all reports be processed?
Yes. Every report that is received by Regulatory Affairs will be processed.
9. What is happening with my report?
That depends on each report, the Regulatory Section and the quality and quantity of information. In general, Regulatory Affairs or the respective Officers will investigate in the case and drive preventive measures. Sometimes feedback from other departments or countries are necessary to close a report.
10. What about my protection as a whistleblower?
CHG-MERIDIAN will not tolerate retaliation of any kind!
Individuals who file complaints or reports in good faith will not be penalized for doing so. If you believe that you or anyone else has been retaliated against or that you or they have been discriminated against in any way for filing a complaint, please report immediately. We will investigate all plausible allegations of discrimination. Substantiated allegations of discrimination by CHG-MERIDIAN will even be prosecuted as a compliance violation.