Modern glass office buildings either side of a reflecting pool

Speak up

How a concern about conduct is raised at Xstreco, and the protection we give the person who raises it.

Raising a concernHow to raise a concernHow a concern is handledWhat the policy providesRaise a concern in confidence

Raising a concern

Anyone may raise a concern about conduct connected with Xstreco. The channels below are open to employees, directors, officers and contractors, and equally to suppliers, community members and any other party affected by our activities. A concern may relate to a breach of the Code of Conduct, of one of our Group policies or of the law, and it may concern the person raising it or someone else.

We do not tolerate retaliation against a person who raises a concern in good faith, and this holds whether or not the concern is ultimately substantiated. Retaliation is itself a breach of the Code of Conduct and we treat it as such.

Our position

We do not tolerate retaliation against anyone who raises a concern.

A concern may be raised anonymously, and we assess it in the same way.

There is no requirement to use the channels in a set order.

How to raise a concern

A concern can be raised through any of the routes below. There is no requirement to use them in a set order, and no requirement to exhaust one before turning to another.

Route
When to use it
Contact
Line management
In the first instance. A concern is usually resolved fastest by the manager or supervisor responsible for the activity concerned, who is closest to the facts.
Your manager or supervisor
Compliance
Central channel. Where the local route is not suitable, or where a concern remains unresolved, it can be raised with our compliance function.
compliance@xstreco.com
Code of Conduct
Central channel. Our dedicated address for matters arising under the Code of Conduct, monitored by the function responsible for conduct.
codeofconduct@xstreco.com
By telephone
Central channel. Our telephone line takes concerns as well as enquiries. Ask at the start of the call to be connected to compliance.
+41 41 562 32 90

The form at the end of this page reaches the same central channel, and can be used without giving a name.

How a concern is handled

We handle concerns promptly, objectively and on the facts. We share information only with those who need it in order to deal with the matter. A concern may be raised anonymously and we assess it in the same way, although limited contact details can make some matters harder to pursue.

1

Acknowledgement

We record and acknowledge a concern raised through one of our central channels within five working days.

2

Assessment

We assess the concern to establish what it involves, who is to handle it, and whether an investigation is required.

3

Investigation

Where an investigation is required, we conduct it fairly, promptly and without bias or conflict of interest. Oversight of investigations rests with executive management.

4

Outcome

We take corrective action where a concern is substantiated. We record and monitor case duration, closure and trends, and we gather feedback on the process after resolution.

What the policy provides

Our Whistleblowing and Ethics Reporting Policy governs how concerns are raised, how we handle them and what protection applies. We set out its principal provisions below.

Who may raise a concern
Current and former employees, directors, officers, contractors and job applicants, and third parties including suppliers, customers and community members. Where we hold an interest in a joint venture we do not control, we use our influence to encourage conduct consistent with the policy.
What may be raised
Suspected fraud, corruption, harassment, discrimination, safety violations and data breaches, and any other breach of the Code of Conduct, of our Group policies or of the law.
Confidentiality
We keep the identity of the person raising a concern, and the details of the report, confidential unless disclosure is required by law or is necessary for the investigation.
Anonymity
Concerns may be raised anonymously where the law permits, through channels that still allow follow-up with the person who raised them.
Protection from retaliation
We prohibit retaliation against a person who raises a concern in good faith, or who takes part in an investigation, and retaliation is itself subject to disciplinary action. Retaliation means any actual or threatened detriment experienced because a concern was raised.
Who is responsible
Responsibility for our whistleblowing arrangements is assigned within the Group and named in the governing policy, and it includes oversight of investigations. Human Resources supports the fair treatment of those who raise concerns. Line managers support their people and escalate reports.
Standards applied
The arrangements are structured against ISO 37002:2021 and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct.
Training
We require whistleblowing and ethics reporting training of every new employee within 30 days of joining, with annual refresher training thereafter and additional training for managers, investigators and higher-risk roles.

Our Group policy sets out in full the requirements governing reporting, escalation, handling and investigation, and the protections available to those who raise concerns. The standards of behaviour these arrangements protect are set out in our Code of Conduct.

Raise a concern in confidence

Thank you. The concern has been received and is recorded and acknowledged within five working days.
The concern could not be sent. Please try again, or write to compliance@xstreco.com.

We treat submissions confidentially and handle them in accordance with our Whistleblowing and Ethics Reporting Policy. We disclose the identity of the person raising a concern only where the law requires it or where it is necessary for the investigation.