File a Report

At Chronofresh, all our employees and stakeholders can report any behaviour that they suspect to be in breach of the values and principles defined in Chronofresh Code of Conduct and Chronofresh Sustainable Procurement Charter, or of the applicable laws and regulations.

To allow you to voice your concerns, we set up the present Whistleblowing system.

For more information on the whistleblowing process, please refer to the FAQ at the right of the page.
To report any behaviour or situation covered by the present Whistleblowing system, please click on File an alert below and follow the instructions displayed on the screen.
To access an alert you’ve already filed, please click on Access an alert

The information you provide through the present Whistleblowing system can be accessed :

First by Safecall, to check the information are complete and ask you additional information if needed;

Secondly, by the Chief Compliance Officer – Ethics Officer of Chronofresh or any other person authorised to handle alerts within Chronofresh.

If you give your email address, you will receive notifications about new comments or questions on your alert, from the Chief Compliance Officer – Ethics Officer of Chronofresh and/or any person authorised to handle alerts within Chronofresh.

Otherwise, we recommend you connect regularly to the platform to check for new messages, with the username and password you’ll have previously defined.

For more information on how to connect to the present platform, please refer to question 2. How is my alert handled? at the right of the page.

1. Who can file an alert? What topics can I report about?

You can use the present whistleblowing platform if:

You are performing your duties within Chronofresh; or
You are not performing your duties within Chronofresh but you wish to file an alert about a situation related to your relationship with Chronofresh.

If you belong to one of the categories above, you can file an alert about:

conducts or situations contrary to the applicable policies and procedures of Chronofresh;
a crime or offence;
a threat or harm to the public interest;
a breach or attempted cover-up of a breach of an international undertaking, law, or regulation; or
serious violations of human rights and fundamental freedoms, the health and safety of people and the environment.

2. How is my alert handled?

Once your alert is filed, it is handled in several stages, under the responsibility of the Chief Compliance Officer - Ethics Officer of Chronofresh.

You’ll be able to access it once submitted, for further follow-up.

To do so:

A username and a password are displayed on the screen once you have submitted your alert. Please save them securely to create an account and be able to connect to the platform thereafter;
If you choose to identify yourself and to share your mail address, you’ll receive this information by e-mail as well.
Step 1 – Entering the information related to the alert:

The information you share are entered into the present platform.

For your alert to be handled and investigated, it’s important to describe the facts you wish to report as accurately, clearly and in as much detail as possible, to provide factual information and supporting your alert with any evidence proving the aforementioned facts (for example: letters, mails, SMS, etc.).

Step 2 – Receiving the alert and sending an acknowledgment of receipt:

Your alert is first read by Safecall, to make sure the information you provided are complete.
As part of this first reading, Safecall may need to contact you to ask for additional information if needed.
The Chief Compliance Officer - Ethics Officer of Chronofresh or any person authorised to handle alerts within Chronofresh is informed by Safecall that an alert has been created.
You’ll receive from the Chief Compliance Officer - Ethics Officer of Chronofresh or any person authorised to handle alerts within Chronofresh an acknowledgment of receipt, within 7 days of receipt of the alert.

Step 3 – Admissibility Analysis of the alert:

For your alert to be deemed admissible:

You must provide sufficiently precise, clear and detailed information and include the elements necessary for its analysis (e.g. letters, e-mails, SMS, etc.);
Your alert must be based on evidence that can be verified and considered reliable (and not on suspicion or vague rumours); and
You belong to one of the categories of persons who can file alerts and your alert relates to one of the topics as provided for by the present whistleblowing platform.
For more information on the above, please refer to the answer to question Who can file an alert? What topics can I report about?
Step 4 – Conducting an investigation when the alert is admissible:

When the alert is qualified as admissible, an investigation is conducted to verify the facts relating to the alert and whether it is confirmed by established evidence.

The investigation is conducted by the Chief Compliance Officer - Ethics Officer of Chronofresh himself, or by the Chief Compliance Officer - Ethics Officer and one or more persons authorised to handle alerts within Chronofresh, appointed by the Chief Compliance Officer - Ethics Officer of Chronofresh.

Step 5 – Follow-up on the handling of the alert with the whistleblower

Throughout the handling process, you’ll be informed on the progress of your alert by the Chief Compliance Officer - Ethics Officer of Chronofresh or any other person authorised to handle alerts within Chronofresh.
The follow-up can be done either through the secured messaging service of the present platform, or according to your preferred contact method.

Step 6 – Closing the alert

Once your alert has been analysed to determine its admissibility and investigated, if applicable, you are informed of its closure in writing by the Chief Compliance Officer - Ethics Officer of Chronofresh or any person authorised to handle alerts within Chronofresh, within 90 days of the sending of the acknowledgement of receipt (see step 2).

Depending on the situation, you are informed of the actions taken resulting from your alert, the measures taken to remedy the facts reported, or the reasons why your alert is considered non admissible, where appropriate.

3. What are the rights attached to my personal data?

The personal data collected are subject to processing, which responsible is Chronofresh, 3 boulevard Romain Rolland, 75014 Paris, acting as Data controller, within the meaning of the General Data Protection Regulation.

The purpose of the processing of personal data is:

Reception and entering whistleblowing alerts into the platform;
Investigation and alert follow-up;
Development of activity data (statistical) from anonym data.

The lawfulness for this processing is based on a legal obligation regarding whistleblowing systems, such as law n° 2016-1691 of December 9^th 2016 and law n° 2017-399 of March 27^th 2017.

Personal data are also processed based on the legitimate interest of Chronofresh, to handle whistleblowing alerts in case of situations contrary to the Code of Conduct of Chronofresh and/or to the policies and procedures of Chronofresh.

These data will be kept for:

30 days after receiving the alert if it’s not admissible;
2 months after closing the alert if it’s admissible but doesn’t result into any disciplinary or legal actions;
2 months after the decision taken following the investigation if the alert results into disciplinary or legal actions, unless further retention is legally requested by the proceedings.

The use of the Whistleblowing system is optional.

However, when it’s used, the alert may contain personal data necessary to qualify the facts and to allow Chronofresh to handle the alert pursuant to the legal and regulatory obligations and the whistleblowing procedure of Chronofresh.

The data processed by Chronofresh are shared through the Safecall tool following your alert on their online platform or via their phone line.

You can choose the level of anonymity of your alert.

Depending on it, Safecall will only share with Chronofresh the information on your identity you accept Chronofresh know.

The recipients of personal data shared through the Whistleblowing system are the Chief Compliance Officer - Ethics Officer of Chronofresh or any person authorised to handle alerts within Chronofresh, and as part of the rights of the defence, the person concerned by the alert.

You have the following rights on your personal data:

Right of access, of rectification and of limitation;
Right to erasure of your personal data provided the alert is related to a situation contrary to the Code of Conduct of Chronofresh and/or to the policies and procedures of Chronofresh
Right of opposition to the processing when you alert is related to a situation contrary to the Code of Conduct of Chronofresh and/or to the policies and procedures of Chronofresh, unless:
- if there are legitimate and imperatives motives prevailing on the data subject’s rights; or
- if the processing is necessary for the recognition, exercise, or defence of a right.
Right to give instructions related to the retention, erasure and sharing of your data after your death.

Persons whose Personal Data is thus processed may exercise their rights by contacting the Data Protection Officer of Chronofresh at the following address: dpo.dataprotection@chronofresh.fr

Some of your personal data are transferred to the United Kingdom where Safecall datacenters are located.

United Kingdom is considered as an adequate country, guaranteeing a sufficient level of protection of personal data.

If you believe, after having contacted us, that your rights with regard to your data have not been respected, you may submit a complaint to the Commission Nationale de l'Informatique et des Libertés (CNIL).

4. What if I want to file an alert via the hotline?

You also have the possibility to file an alert by calling the Safecall phone line.

To do so:

Please call the following number 00 800 72 33 22 55 if you’re located in France.

If you’re located in another country, please refer to the list of Safecall phone line numbers available here: https://www.safecall.co.uk/en/file-a-report/telephone-numbers/

This number is free of charge and available 24/7.

Please choose the language in which you wish to file your alert.
If you wish to file your alert in French, you’ll be put in contact almost immediately with a French-speaker.

You’ll be able to confidentially discuss with the French-speaker on the details of your alert, by answering their questions.

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