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Lefebvre Group’s Ethics Charter

Our ultimate goal is to promote a culture of transparency, trust, integrity and tocarry out our activity in an ethical environment that respects regulations and our internal procedures. You can consult the Ethics Charter here.

Do you have an Alert?

Lefebvre Group’s Whistle-blower Platform is a solution through which risks, negligence, suspected irregular conduct and regulatory breaches can be reported.

You are aware of a serious violation of human rights and fundamental freedoms, human health and safety, or the environment; an act of fraud or corruption; a breach of ethics; a conflict of interest; or any other violation of laws and regulations: Please submit your report to the Lefebvre Group reporting platform below, to your Toovalu interface or to ethics-compliance@lefebvre-group.com (if external).

All complaints will be processed and, where appropriate, preventive and corrective actions will be taken. If necessary, charges will be pressed.

The principles that apply to the processing of the complaints are:

-      Guarantee of confidentiality and protection of the whistle-blower

-      Guarantee of confidentiality of the submitted documents

-      An admissibility study, an exhaustive investigation if applicable and resolution

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The Lefebvre Group platform enables anyone (internal as well as external parties) to report claim concerning any of its companies.

You can access the platform by following this link

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Report Handling Process Steps and Target Timeframes

Step 1 – Receipt The whistleblower submits a report through their preferred channel: the Lefebvre Group reporting platform, the Toovalu interface, or to ethics-compliance@lefebvre-group.com (if external).

The report can be submitted anonymously on the platform. If submitted, an ethics officer is immediately notified. ‍

Step 2 Acknowledgment of Receipt Regardless of the reporting channel used, an ethics officer officially registers the report in the system. This marks the start of the 90-day period. A formal email acknowledging receipt is sent to the whistleblower; if the report is submitted anonymously, the ethics officer notifies the whistleblower via the platform's communication channel. The acknowledgment of receipt is sent within a maximum of 7 days (Sapin 2 legal requirement). ‍

Step 3 – Eligibility & Analysis The ethics officer assesses whether the report meets the processing criteria defined by the group and the applicable legislation :

- If the report is eligible, the ethics officer forwards the case to a team of investigators chosen to ensure the investigation is conducted independently, impartially, and competently. The whistleblower is informed of the names of the appointed investigators. They may request the exclusion of an investigator if they deem it necessary to guarantee impartial processing.

- If the report is not considered admissible, the whistleblower is informed with a reasoned explanation. The eligibility criteria are as follows: the whistleblower must be a natural person, must not derive any benefit from the report, and the report must have been made in good faith.

‍Step 4 – Processing the Report The investigator analyzes the situation, verifies the relevance of the information, assesses the seriousness of the reported behavior, may conduct further investigations, contact the parties involved, and gather additional evidence.

 Step 5 – Resolution Following its assessment, the whistleblower presents its conclusions to the Ethics Committee. The Ethics Committee provides its opinion on the conclusions and recommended measures.

‍Step 6 – Communication The whistleblower and the person concerned receive a summary report of the results and the measures taken. Timeframe: Maximum 90 days from the date of acknowledgment of receipt.

‍Step 7 – Closure The ethics officer closes the report. All closed reports are archived for 3 years and then deleted if no new related report is filed. The Ethics Committee monitors the action plan following the report.

Confidentiality Management

The alert system has been designed and developed within a secure, protective, and confidential framework. Toovalu guarantees confidentiality in the processing of alerts and requires all stakeholders (whistleblower, targeted individual, and witnesses) to respect confidentiality for the proper conduct of investigations.