Introduction

At mci group, we are guided by our company values. These values are the foundation of how we conduct ourselves and interact with each other, our clients, partners, suppliers, and other stakeholders.

mci group is committed to complying with all compulsory laws in the countries we work in and promoting ethical corporate culture by observing the highest standards of fair dealing, honesty, and integrity in our business activities.

Our Business Code of Conduct outlines our policies and expectations for our employee’s behaviour and actions on behalf of the company and its clients. Based on the UN Global Compact principles, our Code expresses the values and beliefs for conducting business responsibly and transparently. It is the minimum level of behaviour and is mandatory for all employees.

We apply our values to our supply chain through the Supplier Code of Conduct

Purpose

mci group encourages reporting any suspected unethical, illegal, corrupt, fraudulent, or undesirable conduct involving our business and protects individuals who raise a Concern (“Reporter”) without fear of victimisation or retaliation.

The Reporting Concerns policy has been put in place to ensure any Concerns raised are dealt with effectively, securely and appropriately. It is intended to inform employees and external parties as to how to report any good-faith Concern or alert (“Concern”) regarding:

• violation of law
• fraud
• bribery or corruption
• harassment or discrimination
• other ethical Concerns.

This policy is provided to all employees when starting their work with mci group, together with our Business Code of Conduct.

Please note that the Reporting Concerns procedures described below are not to be used to report individual employee concerns relating to routine employment matters or grievances regarding company business decisions. Those concerns may be raised to your Managing Director, local Finance or Human Resources (HR) Responsible.

Confidentiality, anonymity, and non-retaliation

All Concerns reported will be treated confidentially following our MCI Group Privacy Statement. The Reporters’ identity will be protected, and the information provided will only be used as is necessary to investigate the Concern.

mci group will not - nor knowingly permit any employee - to retaliate in any way (including any disciplinary action or dismissal) against anyone raising a good faith Concern.

If a Concern is made in good faith and then later unsubstantiated, the Reporter’s identity and the identity of the persons targeted by the Concern will remain protected.

When raising a Concern, you may do so anonymously.

Bad faith allegations

Using the Concern procedures to make malicious or untrue allegations or repeatedly target an employee unfairly will be considered a violation of the company values and subject to employment action.

Procedure for reporting a Concern

Options for reporting Concerns may vary in accordance with local law. All concerns may be reported in compliance with this Policy and/or local law and/or local processes implemented by our offices if they are of a higher standard than this Policy.

Internal reporting

mci group encourages employees to report Concerns internally. Employees who witness or believe, in good faith, that they have knowledge of a case of a serious breach of our company’s business code of conduct, can report any such non-compliance to their line managers, managing director, local HR or Finance responsible.

Should they feel that solution is not possible or satisfactory in terms of follow-up, they can fill out a report on our secured online platform. Access to our online reporting platform: https://report.whistleb.com/mcigroup

External reporting

Concerns raised by external parties can be reported by completing the questionnaire on our secured online reporting platform. Access to our online reporting platform: https://report.whistleb.com/mcigroup

Concerns should include all the relevant information to substantiate the Concern. The Reporter can report anonymously or openly and should make a good faith effort to ensure the accuracy of the information reported. The Reporter can submit any additional documents or information using the secured reporting platform, even after the initial Concern has been raised. 

The Ethics Officer will review the Concern to determine the appropriate steps for its assessment and investigation. If the Concern requires research, it will be conducted by representatives of our Internal Audit, Human Resources or Legal departments or by external specialists, as appropriate.

We may refer the Concern to Business Unit management if said Business Unit management is without conflict of interest and can best address the Concern.

If the Concern is determined to be well-founded, then the Ethics Officer, Managing Director or Business Unit management as appropriate, will take action to address and remedy the Concern.

mci group’s CEO will be informed on a “need-to-know” basis depending on the severity of the Concern.

The Reporter will be notified through the secured reporting platform when the Concern has been reviewed and informed when any relevant investigation is closed.

Any information contained in the report will be kept confidential, except as required by law or where disclosure is necessary to regulatory authorities, law enforcement agencies or professional advisors to the company.

Timeline

mci group will acknowledge receipt of a Concern within seven days.

The timeline for investigation will vary depending on the content and nature of the reported Concern. However, we will provide feedback to the Reporter within three months.

Time limits for storage of personal data

Any data related to a Concern shall be destroyed, stored, or archived in accordance with applicable laws. If the Concern is not followed by legal or disciplinary proceedings, the data will be destroyed within two months of the end of the verification proceedings or archived. If the Concern is followed by legal or disciplinary proceedings, the data will be kept until the end of the legal or disciplinary proceedings or archived.

Data protection

This Reporting Concerns Policy and the methods for treating the Concerns will comply with applicable data privacy laws. 

October 2021