Compass’ SpeakUp, We’re Listening programme, offers you the option to file reports of concerns or suspicion of violations of our Code of Business Conduct and other standards and policies in a confidential or anonymous way either via the helpline or web-intake (together “confidential reporting channel”), should you feel you cannot talk to your manager, a more senior manager or a colleague from a function such as HR, Legal, Finance or Audit. The confidential reporting channel is provided by our new independent third party provider, Convercent by OneTrust, and is available 365 days a year, 24 hours a day, 7 days a week in all of the countries in which we operate in the reporting parties chosen language. Reports received are referred to Group Ethics & Integrity (“E&I”), a function independent from any lines of business, for confidential review and assignment for follow up and/or investigation, as appropriate.

Fundamentally, nothing has changed in how you can report a concern. We have transitioned from Navex Global to Convercent by One Trust as our chosen independent third-party provider to manage and receive calls via the helpline or web-intake. Convercent by One Trust also provides our case management system.

As part of the transition, we have sought to implement a new and improved programme with optimised processes and a more user-friendly confidential reporting channel. With an enhanced people centric focus especially on end-to-end initial concern handling, we aim to ensure the service offered to you and confidence you have in raising your voice is improved. This includes commitments to:

• always acknowledging receipt of your report; 
• following up with details of the assignment for investigation or action taken; and 
• providing a case closure message.

The diagram below sets out the key steps that will occur when you voice your concerns via the Speak Up, We’re Listening programme.

Compass stands in unity with and supports those who demonstrate the character and courage to Speak Up and Listen. Retaliatory conduct or detrimental treatment will not be tolerated, and any concerns raised will be taken seriously and appropriately investigated.

If something doesn’t feel right, follow your instincts. Speak Up, We’re Listening. 
 

Asking questions, being curious and reporting known or suspected misconduct or improper circumstances or behaviours benefits and protects all of us.  We all have a shared duty and individual right to report concerns that circumstances potentially inconsistent with our Code of Business Conduct (“CoBC”) which are being contemplated, occurring, or may have occurred, using Compass’s Speak Up resources.

For queries about or suspected breaches of Our CoBC, tell someone you trust and speak to: 

• your manager or unit manager;
• your local HR manager (“HR”) or Listen Up Champion;
• a member of your country, Regional or Group legal team (“Legal”);
• a member of Group Ethics & Integrity (“E&I”);  
• raise your concern through the Speak Up web-intake; or
• dedicated country phone numbers for the Helpline

If something doesn’t feel right, follow your instincts. Speak Up, We’re Listening. 
 

Reports are assigned a Speak Up case reference and automatically referred to Group Ethics and Integrity (“E&I”) who reviews each report to assess and determine the appropriate manner of following up, including assigning for investigation. The following principles apply for a SpeakUp case investigation process:

• All Speak-Up concerns, regardless of reporting channel, are received and reviewed confidentially by Group E&I and you can remain anonymous when submitting a report if you wish;
• Once the case has been reviewed, Group E&I will advise on next steps including the person that will be assigned to your case for follow up; and
• Where appropriate and to help with progressing the matter, Group E&I may ask some initial questions so that further steps can be taken to resolve or look into the concerns that you’ve raised. Remember to provide as much detail as you can including documents and files, references, dates and times and involved party information when submitting your concern(s) and to check back on your report regularly to keep up to date with how your case is progressing. We are here to support our people in doing the right thing. 

If something doesn’t feel right, follow your instincts. Speak Up, We’re Listening. 
 

Compass will seek to protect the confidentiality of any person making a report in good faith. We want to reassure you that you will not face any form of disciplinary action or detriment in respect of a concern raised in good faith if it is later found to be mistaken or unfounded.

Your identity will not be disclosed without your consent to anyone beyond those dealing with and investigating concerns raised. This includes maintaining a strict need-to--know to receive and act upon the findings or remedial actions, unless this is necessary and proportionate in the context of looking into the matter, undertaking an investigation and/or seeking legal or compliance advice.

Compass strictly prohibits and does not tolerate retaliation or detrimental conduct in response to you raising a concern or being able to raise a concern. Compass will take all reasonable steps possible to protect you from being retaliated against or being subjected to detrimental conduct. If you or someone else close to you experiences retaliation having raised a concern (or being able to), you are strongly encouraged to make a new Speak Up for review by Group Ethics & Integrity.

If something doesn’t feel right, follow your instincts. Speak Up, We’re Listening.

Listen Up Champions (“LUC”) are ambassadors of the Speak Up, We’re Listening programme. LUC’s play a key role in helping to embed the programme, support the employee voice and together with your efforts, collectively strengthen and foster a culture of inclusivity and integrity. Most importantly, LUC’s are accessible to you in your country and available to listen, in confidence, should you prefer to discuss your concerns directly or are perhaps unsure about something you have seen or heard and want a sounding board to help guide what to do next. The choice as to how to raise your voice remains entirely yours, we simply encourage you to Speak Up, We’re Listening. 

After submitting your report, you will be provided a case reference number and asked to create a password. With those two pieces of identification, you can follow up on the report by visiting the SpeakUp portal or contacting your local country helpline.