Ethics & Compliance

We are committed to high ethics business standards in the conduct of our business and in our relations with all stakeholders, as they play an essential role in ensuring our sustainable growth and success. It’s about being upright in our actions so we can progress and be proud of the work we do.

Noatum’s Compliance System is made up of all of the rules, formal procedures and governance functions intended to ensure the that the company conducts itself in accordance with ethical principles and applicable law and to prevent improper conduct or conduct that is contrary to ethics, the law or our rules and values.

The Noatum Code of Ethics is a cornerstone of our ethics and compliance system. It constitutes our common ethical framework, defining the boundaries within we as Noatum employees must act to comply with laws, internal policies and our values.

Download Code of Ethics

Whistleblowing channel

Noatum aims to create an environment of transparency and promote respect by its directors, employees and its suppliers for the law and the rules of conduct established in the Code of Ethics.

Noatum has implemented an internal reporting system to that end, to facilitate the reporting of possible irregular conduct or potential unlawful acts or acts contrary to the law or to the Governance and Sustainability System, impacting the scope of the Group companies, which is based on the following essential principles:

Essential principles

Prohibition of retaliation
Noatum undertakes not to take any form of retaliation against any person who has made a report in good faith.
Anonymity
Communications can be made anonymously
Confidentiality
The confidentiality of the identity of the informant and of any third party mentioned in the communication, as well as the protection of personal data, is an essential principle in the management of the communications received.
Management of the System
The Compliance Department of the relevant company is the body responsible for the management of the Internal Information System in accordance with the procedure established by its respective governing body.
Rights of persons affected
The rights to privacy, honour, defence and the presumption of innocence of the persons under investigation or affected are guaranteed.

Visit Whistleblowing Channel

Speak Up and Whistleblowing Channel Policy

FAQs

What is the Noatum Whistleblower system?

The Noatum Whistleblower system is a confidential channel through which you can raise concerns about suspected serious violations of laws or Noatum Rules in areas such as: insider trading, competition law, IT security, data privacy (GDPR), threats to health, safety and environment, theft and embezzlement, accounting manipulation, financial fraud, corruption, foreign trade controls, human rights and labour rights, work place and/or sexual harassment, retaliation or discrimination.

What does the Noatum Whistleblower system not cover?

The system is only for reporting possible violations made in good faith of laws or regulations*, or issues that may expose Noatum to serious legal risks. The system is not for questions regarding applications for employment, commercial inquires or disputes, ordinary HR complaints (e.g. salary, performance, vacation) or general questions. Such should rather be directed to the relevant Business Unit or respective function in Noatum.
*(including violations of EU laws and regulations as stipulated in EU Directive 2019/1937)

Who administers the Noatum Whistleblower system?

The system is administered by an independent company (ETHIX360) and is available 24 hours a day, seven days a week. It can accommodate reports in more than 60 languages and you can submit a report anonymously if you feel necessary. The system cannot track or identify you. No cookies, IP address or similar is stored.

Who else can I speak to?

If you are an employee in Noatum, we encourage reporting concerns through the channel you are most comfortable with, such as your line manager, another member of management, a relevant supporting function such as Legal, HR or the Noatum Compliance function.
The Noatum Whistleblower system is available as an alternative if you are uncomfortable reporting through other channels. We do not tolerate discrimination or retaliation against reports made in good faith. If you believe you have been retaliated against for reporting or participating in an investigation, you should immediately report this. Any such report will be investigated confidentially.

What happens after I contact the Noatum Whistleblower system?

Once you submit a report you receive a confirmation and a report key and password for the post box in the system for follow-up on your submission.

Your report is initially reviewed by designated individuals within Noatum’s Compliance Departement, who will determine further action. The number of designated individuals involved will be limited to the minimal extent possible.

The post box in the system allows you and the investigating officer to engage, asking clarifying questions which typically result in a more correct outcome of any wrongdoing has taken place.

Accordingly, we ask that you check the post box after a week.

Are reports to the Noatum Whistleblower system secure and confidential?

The system called CaseTrack is hosted on ETHIX360’s secure servers and is not a part of Noatum’s website or intranet. Any report you make will be kept confidential to the fullest extent legally possible. Relevant persons will be notified of and/or involved in an investigation on a “need to know” basis and/or in accordance with applicable national or international rules concerning data protection regulations.

The website is hosted on ETHIX360’s secure servers and is not a part of the Noatum website or Intranet.

Do not use this site to report emergencies or situations that pose an imminent threat to physical integrity, life or property. Reports submitted through this service may not receive an immediate response. If you require emergency assistance, please contact your public emergency services.