misconduct reporting procedure.

procedure

sub title

Purpose

The Misconduct Reporting Procedure gives the steps to follow if you suspect or have proof that serious misconduct has been committed within or in relation to the Randstad Group.

Applicability


The policy applies to all Randstad Group companies.

Status



This procedure replaces the Randstad Integrity Code of 1st November 2005.
To make it easier to digest the new rules, superfluous or redundant passages have been removed and the layout and terminology – including the title – have been improved.

Definitions


Randstad Group


Randstad Holding nv and/or one of its subsidiaries. 

Complainant


Any person, whether or not they belong to the Randstad Group, who – in good faith – submits a complaint, report or concerns about misconduct committed within or in relation to the Randstad Group. 

Professional Code of Ethics (Business Principles)


Value policies
Governance

Local Integrity Officer


Every company and/or subsidiary - including Randstad Holding sa- in the Randstad Group has its own Local Integrity Officer. 

The role of Local Integrity Officer can be held by a Randstad employee or external party. The individual CEO is responsible for deciding which one.

Central Integrity Officer


The Central Integrity Officer is appointed by the Randstad Holding Board of Directors and receives and examines any allegations of misconduct committed by the senior management team of a company and/or subsidiary. They receive periodic reports from the Local Integrity Officers and submit their own reports: quarterly to the Board of Directors and annually to the Audit Committee of the Supervisory Board.

Policy and related documents
 (Misconduct Reporting Procedure)

Compliance with our core statements


Given that it is an international organisation focussed on the excellence of its services throughout the world, the Randstad Group expects all of Group employees and companies to act in accordance with its Professional Code of Conduct at all times. This means acting in line with ethics, with integrity and in accordance with Randstad policies and procedures and all applicable laws and regulations. We expect our employees to help maintain Randstad’s excellent reputation by upholding the ambitious principles expresses by our core statements: to know, to serve, to trust, striving for perfection and simultaneous promotion of all interests. As part of our culture of transparency and responsibility, we encourage all stakeholders to report any incident, situation and instance where conduct has clearly failed to honour these statements. 

To facilitate the reporting of instances concerning serious misconduct committed within the Randstad Group, we have set up special channels using either existing local systems in subsidiaries or the Randstad Group Misconduct Reporting Procedure (see paragraph 2, Misconduct Reporting Procedure, below). All instances reported through official procedures are treated with strict confidentiality (except for the requirements of an enquiry and any ultimate action) and any employee submitting a complaint in good faith can be assured that no retaliatory action will be taken against them.

The Misconduct Reporting Procedure gives the steps to follow if you suspect or have proof that serious conduct has been committed within or in relation to the Randstad Group.  Such misconduct includes serious instances such as those listed below:

Human Rights violations

violations of the Randstad Code of Ethics;

violations of Randstad policies and procedures

criminal offences

failure to comply with statutory or regulatory obligations
personal misconduct or disrespectful behaviour

violations of health and safety regulations

 The Randstad Holding Board of Directors takes full responsibility for the Misconduct Reporting Procedure and its application. It is the specific duty of all Randstad Group managers to see that it is followed in their business entities.

Misconduct Reporting Procedure


Any person with valid reasons for suspecting misconduct or witnessing it is required to report it. In the first instance, those involved are encouraged to report the instance via the normal (local) reporting procedures through local management, local intermediaries such as persons designated to receive this type of confidential information and complaints offices, etc. As a general rule, informing management is recommended as the fastest route. It is also the best way of ensuring that the working environment remains pleasant and transparent throughout the Randstad Group.

The Misconduct Reporting Procedure cannot be used to avoid normal communication procedures. It is designed solely for cases where local mechanisms might not be suitable or effective and is to be used as a last resort.

Reports may be submitted through specific Randstad Group resources i.e. a free 24-hour phone hotline and secure web page. Both systems are managed by an independent external provider. Please see the annex for full contact details and user instructions. Reporting can be anonymous but Randstad would encourage you to provide your identity to facilitate the enquiry.

To reduce instances of suspicious and false reporting and protect personal data, the Randstad Holding Board of Directors will not examine anonymous reports received via any other channels.

Employees should also be aware that, in the absence of a special request or a valid law to authorise it, reporting misconduct via external channels – without having first used internal procedures – may constitute a violation of the contractual or confidentiality obligations binding them to the Randstad Group. Failure to meet these obligations may lead to disciplinary action.

How reporting is handled


Reports received via the Randstad Group channels are sent to the Local Integrity Officer for the country or company in question. As a general rule, a copy is also sent to the Randstad Holding Central Integrity Officer.

The Local Integrity Officer ensures that all reported cases are examined and treated in a legal manner as quickly as possible, and with total respect for the rights of all individuals involved. In certain circumstances, reported cases can be passed on to a local management representative, who will then take them in hand. The same practices relating to anonymity and the absence of any retaliatory action will be applied.

The Local Integrity Officer may decide not to examine a report if:  

There is not enough information to conduct an enquiry properly and if it is impossible to obtain further information;

It appears that it has not been submitted in good faith.

The Local Integrity Officer will confirm receipt of a report to the complainant within 5 working days. Where possible, the complainant will be kept informed of the progress of the enquiry. However, for reasons of confidentiality, it may be decided not to disclose certain details of the enquiry or action taken.

If a report has to be submitted via the normal (local) procedures rather than Randstad Group procedures, the Local Integrity Officer will inform the complainant of the applicable (local) methods.

If the misconduct reported involves senior management at a local head office in a country and/or subsidiary, the Local Integrity Officer will redirect the complaint to the Central Integrity Officer. They will notify local management and inform the relevant member of the Randstad Holding Management Board and/or Supervisory Board. Or they may decide to call upon the Randstad Holding Audit Committee of the Supervisory Board.

Complaints about a member or members of the Randstad Holding Board of Directors or Supervisory Board will be handled by the Randstad Holding Local Integrity Officer.

The appropriate corrective action will be taken quickly when the person or entity in charge of the enquiry sees fit.

Randstad counts on all managers at every level of the Randstad Group treat all misconduct reports seriously and with discretion and to act quickly without taking retaliatory action against the complainant. Managers may take full part in any enquiry into reported misconduct.

Reporting in bad faith


The Randstad Group considers the reporting of allegations in bad faith to be extremely serious. And declaration made by an employee in bad faith will be considered as a serious of the Code of Professional Ethics. If necessary, the Randstad Group might take action against any complainant making a deliberately false accusation or acting for malicious purposes. Such measures might entail disciplinary action, which is likely to lead to dismissal.

Protection, rights and obligations of the complainant


The identity of all complainants will be protected as far as possible and retaliatory action against complainants acting in good faith will not be tolerated. Specifically, the Randstad Group will not take any measures - dismissal, demotion, suspension, threat, harassment or other type of discrimination – against an employee whose action in reporting misconduct is taken in good faith, legal and protected by any law in force. Any appearance of retaliatory action must be reported to the Central Integrity Officer immediately.

Submitting a report does not automatically avoid disciplinary action against complainants involved in the misconduct referred to.

If the complainant is not satisfied with the progress of a complaint or result of an enquiry, they may pursue their complaint via the appropriate channels. When they make a complaint, the complainant is required to continue to comply with all obligations as to confidentiality. They must therefore avoid any form of internal or external disclosure, unless this is a violation of local law where it obliges or authorises that such a report be submitted directly to the competent authority.

Protection and rights of the accused


In principle, where a person is the subject of an enquiry following a report submitted under this procedure, that person will be informed. Randstad will usually inform the person within the next 5 working days. This period can be extended if there is a risk that proof might be destroyed and/or the enquiry obstructed.

Any person who is the subject of an enquiry has the right to respond to the allegations and appeal against any conclusion or ruling made against them.

Data protection, privacy and confidentiality


In the case of a complaint or enquiry, all regulations and laws relating to personal data protection are to be adhered to, including the right to access, correct and delete data.

All personal data connected with the complaint files will be kept strictly confidential, and the privacy of the complainant and the person under enquiry will be protected as far as is authorised by the law and depending on the requirements of the enquiry and, as necessary, the appropriate action to be taken.

Amendments


Having consulted the Audit Committee, the Randstad Holding Board of Directors may modify this policy at any time, whilst respecting the laws and regulations in force, and, as necessary, ask the opinion of the Randstad European Platform and works councils concerned.

Diemen, Holland
July 2009

 

Instructions for using the telephone support service

Direct line (number accessible 24hrs: 800 21048 – Access code: 42108)

The complainant calls the free number and the call is recorded on voicemail. The complainant receives an ID number after making the report. The external provider then sends a verbatim transcription of the recorded message to the Local Integrity Officer for the local head office and/or subsidiary in question. 
To protect the anonymity of the caller, the external provider keeps the recording and destroys it as soon as the Local Integrity Officer confirms receipt of the transcription. 
Using the ID number, the Local Integrity Officer can leave a message of response for the complainant to say that they have received the complaint and, if necessary, ask check questions or issue a conclusion. After the initial complaint, the Local Integrity Officer will leave a response within five working days. 
The complainant can call using the ID number and listen to the response from the Local Integrity Officer. The complainant can opt to answer the questions immediately or later. 


On-line complaint form (Access code: 42108)

The complainant leaves a message on the dedicated web page and receives a special ID number. The external provider translates the message and sends the translation with a copy of the transcribed message to the Local Integrity Officer at the country’s head office or subsidiary in question. 
Using the ID number, the Local Integrity Officer can leave a message of response for the complainant to say that they have received the complaint and, if necessary, ask check questions or issue a conclusion. After the initial complaint, the Local Integrity Officer will leave a response within five working days. 
The complainant can log on again using the ID number and read the response from the Local Integrity Officer. The complainant can opt to answer the questions immediately or later.
 

Randstad Luxembourg Integrity Officer: Luc Feipel

VSO partnership


In 2004, Randstad entered into a major partnership with the NGO Voluntary Service Overseas (VSO). VSO sends volunteer experts into the fields of training, health and corporate management in developing countries. 
Through this global cooperation, Randstad gives aid to the countries most in need of it, helping to build a fairer world.
Randstad works in different ways to support VSO:
- Providing our recruitment expertise for locating volunteers
- Financial contribution
- Sending Randstad employees on volunteer missions out in the field 

For more information about the work of VSO, go to www.vsocan.org.