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In compliance with the French Law n°2016-1691 of December 9, 2016 on transparency, the fight against corruption and the modernization of economic life (the "Sapin 2 Law") amended by the French Law n°2022-401 of March 21, 2022 (the "Waserman Law"), eCential Robotics has set up an internal reporting channel to centralize reports made by whistleblowers.

  • What is a « Whistleblower » ?

A whistleblower is a natural person who reports or discloses, without financial consideration and in good faith, information concerning :

  • A crime
  • A misdemeanor
  • A threat or harm to the public interest
  • A violation or an attempt to conceal a violation of an international commitment duly ratified or approved by France, of a unilateral act of an international organization taken on the basis of such a commitment, of European Union law, or of a law or regulation.
  • Conduct and situations deemed not to comply with the various eCential Robotics compliance provisions brought to the attention of its employees.

Whistleblowers include, but are not limited to, all current and former eCential Robotics employees, consultants and trainees, as well as candidates for recruitment, shareholders and partners.

  • How do I report?

A Whistleblowing alert shall be made exclusively by sending an e-mail to the following address:

Whistleblowers can use their professional or personal e-mail address, or create a new one to remain anonymous.

Please note: all exchanges between the whistleblower and the administrators shall be made via the e-mail address used to send the alert.

  • Who manages the alert ?

Administrators are in charge of analyzing alerts received through the email address mentioned above.

eCential Robotics has designated administrators in consideration of their position within the company. To avoid any conflict of interest and to guarantee the impartiality of the signals’ processing, administrators are not members of the Executive Committee and have no hierarchical link between them.

In addition, administrators are bound by the principle of confidentiality.

  • How are requests processed?

Step 1: Acknowledgement of receipt and preliminary assessment

Once an alert has been launched, administrators acknowledge receipt by e-mail within 7 working days.

Each alert is subject to a confidential preliminary assessment by the administrators to determine whether it falls within the scope of the whistleblowing procedure.

  • If the alert does not fall within the scope of the procedure, the data will be destroyed without delay, unless it is necessary to keep the data in order to demonstrate the abusive nature of the use of the alert system. The Whistleblower will then be informed of the administrators’ decision by e-mail.
  • If the alert relates to objective facts, data and information, the administrators will launch an investigation.

Step 2 : Investigation

Following the preliminary assessment, the administrators will investigate the facts covered by the alert.

The whistleblowing system guarantees confidentiality and respect for the rights of all parties involved in the processing of a professional alert. Administrators undertake to respect the obligation of confidentiality, not to use data and information for improper purposes, to respect the limited retention period, and to destroy and return data and information.

Administrators may conduct interviews with the persons mentioned. To ensure impartiality and avoid cognitive bias, interviews may be carried out by several administrators.

Administrators must keep the whistleblower informed of the progress of the investigation and any action taken within a reasonable period of time, which may not exceed 3 months from acknowledgement of receipt of the alert.

Administrators shall decide which action to take in response to any breaches identified in the alert, such as referring the matter to the hierarchy for disciplinary action, or referring it to the administrative or judicial authorities.

Step 3: Information to the persons concerned by an alert

Persons directly or indirectly concerned (such as witnesses, victims or presumed perpetrators) by an alert deemed admissible are informed by the administrators of the personal data concerning them, to enable them to object, on legitimate grounds, to the processing of such data.

This information is provided as soon as the data is collected. However, where precautionary measures are necessary, in particular to prevent the destruction of evidence relating to the alert, these persons are not informed until such measures have been taken.

The data that may be included in this information notice are :

  • The contact details of the Data Protection Officer;
  • The purposes of the processing for which the personal data is intended, and the legal basis for the processing;
  • The categories of personal data concerned;
  • The recipients or categories of recipients of the personal data, if any; and
  • Where applicable, the fact that the controller intends to transfer personal data to a third country or to an international organization, and the existence or absence of an adequacy decision issued by the Commission or, in the case of transfers referred to in Article 46 or 47, or in the second subparagraph of Article 49(1), the reference to the appropriate or adequate safeguards and the means of obtaining a copy of them or the place where they have been made available;
  • How long the personal data will be kept or, where this is not possible, the criteria used to determine this period;
  • The existence of the right to request access to, rectification or erasure of personal data from the controller, or a restriction on the processing relating to the data subject, or the right to object to processing and the right to data portability;
  • The right to lodge a complaint with a supervisory authority;
  • Processing of personal data

1 / Legal basis

The collection of personal data as part of the whistleblowing procedure is justified due to the compliance with a legal obligation. The drafting and implementation of this procedure is in line with French Law no. 2016-1691 of December 9, 2016 on transparency, the fight against corruption and the modernization of economic life (the "Sapin 2 Law") as amended by French Law no. 2022-401 of March 21, 2022 (the "Waserman Law").

The collection and processing of personal data is necessary to process the alert.

2 / Données traitées

The following data (personal or otherwise) may be collected by the administrators:

  • The identity, function and contact details of the whistleblower;
  • The identity, function and contact details of any persons who may be the subject of the alert;
  • The method of reporting;
  • The identity, function and contact details of the administrators involved in collecting or processing the alert;
  • The facts reported and any evidence;
  • Information gathered in the course of verifying the facts reported;
  • Report on verification operations;
  • Follow-up given to the alert.

Personal data processed as part of an alert is subject to the principle of data minimization, which suggests that only relevant data should be retained.

3 / Data retention

Personal data collected will be kept for as long as is necessary to process the alert, including the duration of the investigation and the time required to complete any disciplinary or legal proceedings, or until any appeals against the decision are time-barred.

Data will be archived for a period of 5 years, in order to guarantee the whistleblower's protection or to enable the detection of ongoing offences.

If no action is taken on an alert that does not fall within the scope of the alert system, the data will be deleted within 2 months by the administrators. This period begins as soon as the whistleblower is notified that the alert is inadmissible.

4 / Data subjects’ rights

Persons entitled to exercise their rights include the whistleblower, as well as any person concerned by the alert (alleged victim, witnesses, persons heard during the investigation, alleged perpetrator, etc.). The following rights may be exercised:

  • Right of access: this right is limited to the requester's personal data. This right does not make it possible to subvert the principle of confidentiality, in particular in order to know the identity of the whistleblower. However, this limitation does not preclude the rules of procedural law, fundamental freedoms and, in particular, the adversarial principle.
  • Right of rectification and deletion: this right must not allow the retroactive modification of elements contained in the alert or collected during the investigation. The exercise of this right must not make it impossible to reconstruct the chronology of any modifications to important elements. This right may only be exercised to rectify factual data whose material accuracy can be verified, on the basis of supporting evidence.
  • Whistleblower protection

Whistleblowers acting in compliance with this procedure and its conditions benefit from various forms of protection. This protection applies not only to the whistleblower, but also to any natural person (colleague, relative, etc.) or legal entity (trade union, etc.) who has helped the whistleblower to make the report (hereafter referred to as the "Beneficiaries").

1 / Confidentiality of identity guaranteed

eCential Robotics guarantees the confidentiality of the whistleblower’s identity, the persons concerned and any third party mentioned in the alert.

Nothing that could identify the whistleblower may be disclosed without the whistleblower's prior consent.

In the event that administrators are required to report the facts subject of the alert, to the judicial authorities, information likely to identify the whistleblower may be passed on to them. In this case, the whistleblower is informed.

2 / Civil non-liability

Compliance with this procedure and its conditions guarantees that the Beneficiaries will not be held liable, and in particular will not be ordered to pay damages for any harm caused by the alert.

3 / Criminal non-liability

Compliance with this procedure and its conditions guarantees that the Beneficiaries will not be held criminally liable.

This non-liability applies to offences (i.e. an act prohibited by law and subject to criminal penalties), which may have been committed in order to obtain the documents needed to prove the information contained in the Report.

However, no offence must have been committed in order to obtain the information in the first place.

4 / Protection against reprisals, including disciplinary measures

Protection is provided against any retaliatory action, including any of the following:

  • Suspension, layoff, dismissal ;
  • Demotion or refusal of promotion;
  • Transfer of duties, change of workplace, reduction in salary;
  • Suspension of training;
  • Negative performance appraisal;
  • Disciplinary measures ;
  • Discrimination ;
  • Non-renewal of a fixed-term or temporary employment contract.

Should such measures be imposed against the Beneficiaries of protection, in violation of the guarantees offered by this procedure, the whistleblower may request the cancellation of a retaliatory measure or defend himself in civil or criminal proceedings.

  • Miscellaneous provisions

This procedure is not intended to replace the legal provisions or limit the role of trade unions, the labor inspectorate or the industrial tribunal, as provided for by law.

If the whistleblower feels that the response provided by the administrators is inadequate, he or she can report the matter externally to a competent authority in accordance with the procedures laid down by law.

For further information, please consult : Corporate whistle-blowers |

  • Request for interpretation

Any person, internal or external to eCential Robotics, may send a request for interpretation of the procedure to the following address:

The purpose of this request for interpretation is strictly limited to the interpretation of the provisions of the procedure or of the texts, laws, or policies mentioned or covered by it, and must not be intended to send any alert or to denounce individuals.