Reporting serious and sensitive concerns

To help you assess whether an incident is a serious or sensitive concern and to find the most appropriate reporting channel, please read the guide below. 

The guide is not exhaustive in terms of what can be reported under the Speak Up policy and provides an overview on the types of incident reporting for all stakeholders. You should always apply your personal judgement before submitting a Speak Up report. 

Confidentiality 

All communication will be anonymous and confidential unless you directly instruct otherwise. You are encouraged to identify yourself and explain your concern in sufficient detail to facilitate investigation of the matter. Follow-up questions and investigation may not be possible unless the source of the information is identified. In order to assist ISS in conducting an investigation of a complaint, please provide as much information as possible. ISS will treat all concerns and issues raised under this policy in a confidential manner except to the extent necessary to conduct a complete and fair investigation. The identity of the complainant shall be kept confidential. 

Read our Speak Up policy

Reporting of incidents at the workplace 

- ISS operates on sites at many locations around the world, and errors or behaviour of employees that do not meet our values and code of conduct must be raised with the relevant ISS manager or department. 

- Matters concerning serious harm or death to people, violent or discriminative behaviour, including sexual harassment in the workplace, or violations of human rights, including modern slavery in the workplace, are considered as serious or sensitive concerns. These can be reported globally under the Speak Up policy, if you have not been successful in addressing these with the ISS manager or the People & Culture department. 

Reporting of theft and misappropriation of company or client assets 

- Thefts or misappropriation of ISS’ or a clients’ assets by an ISS employee or manager, should be addressed with the direct manager or the legal department. If you cannot address this with the manager or legal department, you should inform the Chief Financial Officer. 

- In cases where you cannot address theft or misappropriation with management in your local ISS organisation, you can consider reporting the incident under the Speak Up policy. 

Reporting of fraud 

ISS has a zero tolerance policy towards employees and/or business partners that commit fraud. Fraud is deliberate deception to secure unfair or unlawful gain. Fraud can take many forms at all levels of an organisation. A few examples are presented below, but is by no means, an exhaustive list of possible fraud in our business. 

- An example is the falsification of time and attendance records or pay rates, which may lead to payment of excessive wages to the person receiving the payment. If you experience this type of fraud in the workplace, you should normally contact the payroll department. 

- Fraud can also occur in cases where suppliers or subcontractor collaborate with ISS managers to overcharge ISS for the goods or services they provide. If you become aware of collaboration with suppliers or subcontractors, you should normally contact the legal department or chief financial officer. 

Reporting of violation of law 

- ISS strives to be a law-abiding corporate citizen across all the countries where we are present and operates our business in compliance with international and local laws and regulations. In particular, ISS has issued internal policies to ensure compliance with anti-corruption and competition laws. 

- Violations of anti-corruption and competition laws are considered serious and sensitive concerns, which can be reported under the Speak Up policy. 

Report an incident through our Speak Up tool, or telephone hotline. 

We have established management procedures to ensure that the information, including contact information, that you provide to us through the Speak Up tool is treated with strict confidentiality. You also have the option to enquire on the status of an ongoing investigation.  

- Please note that there may be legal restrictions on what you are permitted to report anonymously in the jurisdiction that you are reporting from. Furthermore, the Speak Up policy is regulated under Danish data protection legislation, which means that ISS is required to dismiss and delete any report that is not of a serious or sensitive nature. Your report may therefore be dismissed under the Speak Up policy simply because it has not been addressed to the correct reporting channel.  

- In exceptional cases where it is likely that following the above procedure would interfere with the investigation, the Business Integrity Committee may authorise that we deviate from the procedures described above. However, we will not disclose your identity or contact details unless you have given us your explicit permission in advance. 

Process overview:

1. Report: Reports that are submitted through our Speak Up system are transmitted through a secure and encrypted communications line to Group Internal Audit.

2. Review: Group Internal Audit will assess if your reported concern meets the requirements for processing the report under the Speak Up policy. It will be thereafter reported 
to our Business Integrity Committee.

3. Action: Investigation, actions and feedback to the user.