Code of Conduct
The success of the Pierce Group (“Group”) depends on us doing the right things but, also, on us doing them in the right way. Pierce’s Code of Conduct (“Code”) helps us to do this. It provides guiding principles to show you how to conduct business and it sets expectations for our behavior towards each other, our customers, our products and brands, and other parties.
The Code stresses the importance of following all applicable laws and regulations as well as our internal policies and ethical standards. The Code applies to all Pierce employees and anyone working for, or on behalf of, Pierce irrespective of job function or seniority. We are all expected to read, understand, and comply with the Code and all Group policies.
Whistleblower
Whistleblowing function
Pierce aims to encourage a transparent and open business environment. We abide by the Code of Conduct that is based on the idea that we should operate profitably while maintaining good ethics. It is of the utmost importance to Pierce that all business operations are characterised by the highest possible standards of responsibility, openness and honesty.
Via this reporting channel, you can report misconduct within Pierce. This whistleblower function is administered by PwC on behalf of Pierce.
What is a whistleblower matter?
A whistleblower matter is a report/matter in a work-related context regarding information on misconduct which is of a public interest. To be of public interest, it should concern serious misconduct. This could be for instance financial crime, bribery, environmental crime, major security risks, discrimination and harassment. There is no limitation that the misconduct must have been committed by a person that holds a leading or key position.
Who can whistle blow?
The following categories of persons are encouraged to report misconduct:
- Employees (including part-time or fixed-term employees)
- Temporary agency staff (such as consultants or other independent contractors)
- Persons carrying out internships or volunteer work
- Members of the board
Shareholders - Business partners (for example, consultants or suppliers). Customers or clients are not included among business partners and are therefore not covered by the Whistleblowing Act.
The whistleblower service can also be used by persons who have not yet initiated a work-related relationship with Pierce, provided that the information about misconduct has been acquired during the recruitment process or through other negotiations prior to the conclusion of agreements as well as persons who belonged to one of the personal categories above and have received or obtained information about misconduct during the time in the business.
When reporting a misconduct, you must have reasonable grounds to believe that the information about the misconduct is true at the time of reporting. However, you are not required to present any evidence or the like. As long as you act in good faith, you will not face any negative consequences, even if the suspicion of misconduct after closer investigation turns out to be erroneous.
A whistleblower service should not be used for reporting personal misconduct that only affects the person reporting and their work situation. Such misconduct is dealt with internally and is not compatible with the public interest requirement.
Examples of situations when the feature should not be used are:
- conflicts between the person reporting and another co-worker
- views on leadership
- dissatisfaction with wage setting
Although these conflicts and expressions of dissatisfaction are important to deal with, in most cases they are not of public interest and should be handled internally in the respective manager reporting lines or local or Group HR.
What about protection for the whistleblower?
It is prohibited for an employer to expose an employee to reprisals, for example in the form of termination or relocation due to his or her whistleblowing. The whistleblower function provides the whistleblower with complete anonymity and the company is not allowed to investigate the identity of the whistleblower.
Reporting
Access to the whistleblower function/system is found via the following link: https://whistleblowersoftware.com/secure/9695fe27-7f57-4f63-9021-9d42c2984c2b.
Privacy and IT security
The whistleblower function uses ISO 27001 certified hosting suppliers and internal processes and product features are built to comply with whistleblowing laws and privacy laws and regulations. The whistleblower function is built with Privacy By Design principles. “