Non-Compliance / Ethical Violation Whistleblowing System

All Kuehne+Nagel employees, whether permanent, external or occasional, as well as contractors, Kuehne+Nagel business partners or other third parties with an interest in acting are encouraged to prevent, detect and report any violations of applicable laws and regulations or the principles of the Kuehne+Nagel Code of Conduct.

For example, the following may be reported: 

• Any violation of the provisions of the Kuehne+Nagel Codes of Conduct,
• Any serious violation of human rights, fundamental freedoms, human health or safety, or the environment,
• Any suspected or proven act of corruption or influence peddling, favouritism or unlawful taking of interest or misappropriation of public funds or property of Kuehne+Nagel or its customers,
• Any suspected or proven anti-competitive practices,
• Any crime, offence, or violation of an international commitment ratified by France,
• Any breach or violation of export control and economic sanctions regulations ("Trade compliance"),
• Any breach or violation of the provisions relating to the Protection of Personal Data ("French Data Protection Act" or "GDPR"). 

The whistleblower, within the framework authorised by the regulations in force, may thus be :

• A permanent, temporary or occasional employee of Kuehne+Nagel,
• A co-contractor of Kuehne+Nagel or an employee of the latter,
• A third party authorised by the regulations in force.

The whistleblower benefits from legal protection as defined by the regulations in force. 
Reports can be sent by post or email to the General Management of Kuehne+Nagel France, Kuehne+Nagel Switzerland or to the Compliance Department at compliance@kuehne-nagel.com.

You must describe the facts objectively and in detail, provide the information and elements that lead you to make a report and, if necessary, attach the corresponding evidence (photograph, document of any kind). 
Upon receipt of your report, you will be sent an email marked "confidential" acknowledging receipt of the report.
In addition, you will be informed within two months, by email marked "confidential", in the same way as the persons concerned by the report, of the admissibility and follow-up given to the report and its possible closure. 

The recipients of the report are the members of the Risks & Compliance Committee of Kuehne+Nagel France and Kuehne+Nagel Switzerland. 

The members of the Risks & Compliance Committee will treat the report confidentially, independently and in accordance with the internal procedure in force. They may, if necessary, be assisted by members of the audit unit. The investigation will result in a confidential internal report to Kuehne+Nagel's senior management, which will decide on the follow-up to be given and, in particular in application of its procedures, decide on any actions and/or sanctions. The General Management may also, at its discretion, decide to refer the matter to the judicial authorities.
You are guaranteed the confidentiality of the content of your report: your identity, that of any persons concerned and the facts which are the subject of the report will also be treated confidentially, including in the event of communication to third parties, strictly limited to the sole needs of verification or processing of the report. 

In addition, spontaneous disclosure to the judicial authorities of any element of a nature to allow your identification will be subject to obtaining your prior consent. However, Kuehne+Nagel will not be able to oppose the injunction of the judicial authorities.
If you wish to remain anonymous, please provide us with an email address that does not allow you to be identified.

If no action is taken on the report, all elements of the report file and their copies will be destroyed when the report file is closed.
The whistleblower must act in good faith and without intent to harm anyone. Misuse or fraudulent use of the whistleblowing system may expose the perpetrator to legal action. 
The use of the system in good faith, even if the facts subsequently prove to be inaccurate or do not give rise to any follow-up, may not expose the author to sanctions or reprisals. 

Protection of personal data: The information you submit will be processed primarily in France, Switzerland or the European Union in accordance with French and European regulations on the processing of personal data.
In accordance with the law of 6 January 1978, all persons have the right to access and rectify data concerning them. You may exercise this right by sending your request to the Data Protection Officer at: privacy-france@kuehne-nagel.com. If you do not receive a reply, you can lodge a complaint with the French Data Protection Authority (CNIL).