The reporting form is available for all employees of the Sagemcom Group, as well as to its external and occasional collaborators, namely any person collaborating in a professional framework with one of the entities of the Sagemcom Group. It allows to report confidentially to our ethics line any situation that would be contrary to the rules described in our guide to the prevention of corruption and / or code of conduct (accessible on the next page), as well as to any situation constituting or likely to constitute a crime or a serious and manifest violation of an international undertaking duly ratified or approved by a State in which the Sagemcom Group carries on its activities or which is applicable to it, of a unilateral act of an international organization taken on the basis of a such commitment, the law or regulation, or a serious threat or prejudice to the public interest, of which the issuer has personally been aware.
The issuer choosing to use the reporting device must do so only:
- whether it has sufficient and objective reasons to believe that irregular or inadequate facts or conduct could present a serious risk to the Sagemcom Group;
- If he or she is aware of the professional reporting procedure.
Use of the reporting form is optional. As such, no penalty may be imposed on the employee on the grounds that he has not used it. For all ethical issues, you can also contact the Sagemcom Quality, Ethics & Risk department directly.
Sagemcom is committed to ensuring the strict confidentiality of the issuer's identity at all stages, from reception to processing of the reported situation. It may not be disclosed unless the law or the regulations provide otherwise.
Under no circumstances may the issuer be subject to reprisals, penalties or pressures of any kind as a result of a bona fide allegation, even if the facts subsequently prove to be inaccurate or give rise to after. If this is the case, he should immediately report to the Quality, Ethics & Risk Manager and the CSR Officer who will take all appropriate measures to protect the issuer in such circumstances and stop the treatment.
Nevertheless, any issuer that makes a bad faith report may be subject to disciplinary proceedings or even criminal sanctions under the regulations of the country concerned.
By clicking on the following, I acknowledge that I have read the reporting procedure.
Sagemcom Holding, responsible for processing, implements personal data processing for the purpose of managing and monitoring the professional reporting procedure. For the implementation of this treatment, Sagemcom Holding has undertaken a commitment to comply with French Decision No 2017-191 of 22 June 2017 authorizing the automatic processing of personal data used in the framework of the professionnal alert system (AU-004). The collection of data is limited to the information strictly necessary for the effective use of the alert system. They are mandatory. Failure to provide such information may result in the alert not being taken into account. This data is intended for authorized persons of the Sagemcom group, according to their authorizations, as well as to its subcontractors and possible service providers. If the alert is considered to be outside the scope of the alert system or is not followed by verification, the data will be archived after anonymization of the alert form and the verification report of the alert, and destroyed without delay in respect of any documents produced in support of the alert. The data collected and subject to verification operations will be anonymized and archived within 2 months after the closure of the verification operations, where the report is not followed by a disciplinary or judicial procedure, or after proceedings and limitation periods where disciplinary proceedings or legal proceedings are brought against the person charged by the alert or the perpetrator of an improper report.
Anonymous archived data will be retained to generate reports and analyze trends. The data subject to archival measures shall be retained, within the framework of a restricted access information system, for a period not exceeding the time-limits for contentious proceedings. Where necessary to take corrective action or where required by local law, personal data may be stored outside the system in a paper database by authorized personnel when the alert is not followed disciplinary or judicial proceedings or, as the case may be, at the end of the proceedings and limitation periods. The legal basis for the treatment is compliance with the legal obligations to which the Sagemcom Group is subject and, in particular, French Law 2016-1691 of 9 December 2016 on transparency, the fight against corruption and the modernization of the economic life. You have the right to interrogate, access, rectify, erase, limit and oppose all data concerning you in connection with this processing. You also have the right to formulate specific and general guidelines for the preservation, erasure and communication of your post-mortem data. These rights are exercised by postal mail accompanied by a copy of an identity document signed to Sagemcom, Quality, Ethics and Risks Director, 250 route de l'Empereur, 92500 Rueil-Malmaison, as well as a right of complaint to the national data protection authority.
Data processing takes place in France. However, Sagemcom may communicate information to recipients established outside the European Union in countries with or without data protection considered by the European Commission to be equivalent to the sole purpose of processing alerts (analyzes, surveys , research ...). It is impossible to determine these countries to the extent that this will depend on the alert. In any event, where the addressees are established in a country which does not have a protection recognized as equivalent by a decision of the European Commission, then Sagemcom will regularize with the recipients the standard contractual clauses on the basis of those defined by the European Commission to obtain the guarantee of the latter that the reported data relating to the alerts as described will be treated in a manner equivalent to that which would have been processed in Europe. In any event, the issuer of the alert will be informed of such flows as well as the person concerned after, if necessary, for the latter to take into account precautionary measures.
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