WHAT IS WHISTLEBLOWING?

A whistleblower is a person who reports to TEAM Group or relevant authorities any activity or conduct that he or she considers or suspects to be illegal, dishonest, unethical, contrary to TEAM’s policies or codes, or otherwise improper. A whistleblower could be a direct victim or merely know about the reported violation.

POLICY STATEMENT

TEAM Group shall:

1. Prohibit all forms of retaliation against: (1) Any whistleblower who in good faith reports or attempts to report actual or suspected violation of laws, regulations, TEAM Group’s policies or codes, including any employee who raises issues, complaints, suggestions, or feedbacks about workplaces. (2) Any witnesses or any other employees involved in investigations of whistleblowing reports;
2. Provide at least one channel where employees can anonymously: (1) report violations of laws, regulations, or TEAM Group’s policies or codes including violations against this Policy itself; and (2) raise issues, suggestions, or feedbacks. Anonymous channel is defined as a channel whereby a user does not have to reveal his or her identity.

TEAM GROUP’s ANONYMOUS WHISTLEBLOWER HOTLINE
+1 (905) 940-9334 Ext. 2281

3. Protect whistleblowers or any other employee involved in the investigation, including witnesses from potential retaliation;
4. Investigate any reported violations from whistleblowers and/or any employee;
5. Keep confidential whistleblowers’ and witnesses’ identities and information included in the whistleblowing reports. Relevant Information shall be disclosed only to persons involved in the resulting investigation process such as witnesses. Disclosure to other persons is acceptable only when it is required by law, regulation, or court decision;
6. Keep all communication from all employees confidential except if such disclosure is required by law, regulation or court decision and protect all employees from any resulting reprisal.

This Policy is applicable to all TEAM employees. The Policy applies to all instances of whistleblowing or complaint reporting received.

WHAT IS RETALIATION?

Retaliation in workplace is generally any action, statement, or behavior that is expressed adversely to punish a whistleblower for reporting or attempting to report whistleblowing events or to punish any employee who raises issues, suggestions, and/or feedbacks about workplaces or to discriminate. It can occur when anyone takes an unfavorable action against an employee due to his/her engagement in reporting workplace concerns or collaborating as witnesses or investigators in the investigation process.

Act(s) of retaliation may come in various forms including verbal or non-verbal behaviors. Examples of retaliation include:

• Intimidation, threats, coercion, or discrimination;
• Deduction or withholding of compensations or benefits;
• Demotion, suspension, or termination of employment;
• Harassment or bullying;
• Changing work responsibilities or assignments without prior notice;
• Taking away opportunities for career advancement;
• Excluding an employee from important meetings in which they are involved in the topic;
• Threatening or intimidating in any possible way an employee who has made a report;
• More subtle actions, such as isolating, ostracizing, mocking, or falsely accusing the employee of poor performance and any other manner of discrimination.

REPORTING RETALIATION PROCEDURES

TEAM Group considers having reporting procedures very important. Anyone may report, with genuine and sincere concern, actual or suspected violation of this Whistleblower Policy to TEAM throughout several channels available both internally and externally with guaranteed confidentiality.

TO REPORT A VIOLATION OF THIS POLICY PLEASE EMAIL whistleblower@team-group.com
OR CALL TEAM +1 (905) 940-9334 Ext. 2281

INVESTIGATION PROCEDURE

TEAM Group takes seriously all whistleblowing and complaint reports and investigate them fairly and transparently. The investigation shall be conducted in a fair and balanced manner with the purpose of objectively ascertaining what transpired. All information from the investigation will be shared on a strictly need-to-know basis in order to preserve confidentiality. We maintain and implement the same highest standard for the investigation process of all reported cases including allegation of retaliation in the workplace.

Relevant Information shall be disclosed only to persons involved in the resulting investigation process such as witnesses, and they are also required to keep all relevant identities and information confidential. Disclosure to other persons is acceptable only when it is required by law, regulation, or court decision.

The assignee investigator, being as the case may be, local, regional or a corporate HR representative, will take appropriate action based on objective criteria to address the concerned violation and timely inform the whistleblower of step(s) taken. If need be, exchanges preserving confidentiality will take place with the whistleblower.

The assignee investigator may assign the report to another appropriate investigator (e.g., legal department, internal audit, or external law firm), who will be submitted to the same stringent rules of utmost confidence.

CONFLICT OF INTEREST: SHOULD A REPORT REFLECT A RETALIATION CONCERN RELATING TO AN INDIVIDUAL MENTIONED ABOVE (FOR EXAMPLE A MEMBER OF HR TEAM, ETC.), SUCH INDIVIDUAL WILL NOT BE ALLOWED TO INVESTIGATE THE CASE.

POLICY IMPLEMENTATION

The Human Resources department shall strictly enforce and localize the implementation of the Whistleblower Policy, subject to relevant laws and regulations. TEAM Group shall consider the following essential aspects:

• Communication of the Policy to all levels of employees;
• System for listening to and resolving employee’s whistleblowing events;
• System for receiving and responding to reports of retaliation;
• Strict chain of custody of information to ensure confidentiality throughout the process of handling whistleblowing or grievance reports;
• Potential disciplinary measures for employees engaged in retaliation;
• Periodic review of Policy effectiveness including monitoring and review of retaliation cases and how they are handled.

CONSEQUENCES OF VIOLATING THE POLICY

A TEAM employee, officer or manager who retaliates against someone who has reported a violation in good faith may be subject to disciplinary action up to and including termination of employment.

RESPONSIBILITY

TEAM Human Resources is responsible for monitoring and updating this Policy.