Speak Up, We’re Listening is Compass Group’s reporting programme, that offers you the option to report your concern or suspected violations of our Code of Business Conduct (“our Code”) and other standards and policies in a confidential or anonymous way.

Our confidential reporting programme is available 365 days a year, 24 hours a day, 7 days a week in all of the countries in which we operate, in your chosen language.

Reports received are referred directly to Group Ethics & Integrity (“E&I”). E&I are a dedicated team of caring and trustworthy professionals, independent of any other lines of business, who confidentially review and assign reports for follow up and/or investigation, as appropriate.

We want to reassure you that you can raise concerns in good faith without fear of retaliation, even if those concerns turn out to be mistaken or unfounded.

We want to help everyone find the right help and support for their concerns or issues as quickly and efficiently as possible. Where your concern does not relate to a possible violation of our Code of Business Conduct or concerns regarding any unethical, illegal, or other improper circumstances or behaviours you should use the following resources:

• For operational Health, Safety & Environmental (“HSE”) issues, contact your local HSE manager,
• For concerns relating to your own employment position or circumstances at work including grievances* that do not relate to a possible violation of our Code we encourage you to raise these concerns directly with your line manager, your unit manager, or your local Human Resources team.

*Examples of grievance may include interpersonal conflict with your manager or another colleague or challenges to reviews in relation to performance, promotion, work arrangements or disciplinary action.

For more information, refer to our Speak and Listen Up Policy on our website.

Our Code applies to everyone working with, for or on behalf of Compass, including without exception temporary and contract staff regardless of location, role or level of seniority. We also encourage our business and supply chain partners (and their workers) to use Compass’s Speak Up programme to raise a concern about improper circumstances including those which may be inconsistent with our Global Supplier Code of Conduct (our “Supplier Code”).

We all have a shared duty and individual right to report concerns that circumstances potentially inconsistent with our Code or Supplier Code (together are “our Codes”) which are being contemplated, occurring, or may have occurred, via Compass’ Speak Up programme.

Breaches of our Codes, standards, policies and procedures may include but not be limited to;

• bribery and corruption,
• conflicts of interest,
• fraud,
• theft,
• competition issues,
• financial irregularities,
• false accounting,
• financial misstatements and misrepresentations,
• money laundering,
• terrorist financing,
• tax evasion,
• failure to comply with, or breach of, legal or regulatory requirements including disclosure obligations,
• retaliation,
• illicit drugs or substance abuse,
• bullying or harassment,
• discrimination,
• threatened violence,
• violence,
• sexual harassment,
• sexual assault,
• criminal damage against property,
• human rights issues,
• modern slavery,
• child exploitation,
• the infringement of indigenous peoples' rights,
• conduct causing danger to people, the environment or the financial system.

Reports are assigned a Speak Up case reference and automatically referred to 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 Speak Up case investigation process:

• All Speak-Up concerns, regardless of reporting channel, are received and reviewed confidentially by E&I and you can remain anonymous when submitting a report if you wish (subject to local law requirements);
• Once the case has been reviewed, 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, 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 and partners 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 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 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 E&I.  To ensure the integrity of the Speak Up process, you are also expected to respect the principles of confidentiality and fairness regarding the information you have provided and engagements with E&I.

We all know that speaking up is the right thing to do. But just because it’s right doesn’t mean it’s easy. It can be hard to know when and how to say something, and we may be unsure of who to talk to about our concerns.

For queries about suspected or actual breaches of our Codes, we should tell someone we trust, in the way we feel most comfortable with, using any of our Speak Up resources:

• our line manager or more senior manager
• our local Human Resources manager or Listen Up Champion*
• a member of our country, Regional or Group legal team
• a member of Group Ethics & Integrity
• or when ready, raise our concern through the Speak Up platform

*Listen Up Champions (“LUC”) are ambassadors of the Speak Up, We’re Listening programme. 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.