Our Speak and Listen Up Policy | November 2021
Protect Our People. Protect Compass.
1

Introduction

1.1

At Compass Group our people andculture make the difference in what wedo and how we service millions ofconsumers around the world. We arecommitted to conducting our businesswith honesty and integrity creating an
inclusive environment where people feelempowered and safe to Speak and
Listen Up.

1.2

We expect all Compass personnel,
including directors, officers, employees,
workers, consultants and contractors
anywhere in the World (referred to as“you” in this policy), and agents,
intermediaries, consultants, suppliers,and other business partners (“Business
Partners”) to uphold these standards andto act in accordance with our values andthe Compass Group Code of BusinessConduct (”our CoBC”) and related
policies as well as with all applicable
laws.

1.3

We value and foster a culture of integrity
based on principles of openness, trust
and accountability and encourage you
and our Business Partners to Speak Up if
something doesn’t feel right. Everyone at
Compass has a duty and responsibility to
Listen Up to those who raise their voice,and do the right thing by following up.

1.4

We encourage you touse our Speak Up resources below toseek guidance on ethical or compliancedilemmas and issues. We want you toexpress your views freely and to report,
in confidence, any concerns regarding
any unethical, illegal or other improper
circumstances or behaviours whichsuggest our CoBC is not being followed.
For more information on confidentiality
and protection against retaliation referto sections 9 and 10 below.

2

Purpose

2.1

The aims of this policy are to:•••assure you that we are here to listen
and to empower you to raise yourconcerns in good faith in a way thatyou feel most comfortable with prior tousing our Speak Up helpline;
inform you of your options where andhow to raise your voice and refer yourconcerns;
provide guidance on how to raise thoseconcerns including the role performedby Group Ethics & Integrity, a
dedicated central team - independentof any other lines of business - which
oversees and manages our global
Speak Up programme, including theinitial review of reports received
through the Speak Up platform (webintake) & helpline;

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•

•

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remind you, as part of upholding ourvalues, it is your duty and right topromptly raise concerns in theknowledge they will be taken seriously,
followed up and/or investigatedappropriately;
provide reassurance that you can raise
any concerns in good faith without fearof retaliation, even if those concerns
turn out to be mistaken or unfounded;andprovide transparency about how
concerns will be managed and followed
up appropriately, demonstrating
Compass’ commitment to listening up.

3

Scope

3.1

This policy applies to all Compass
personnel, working at any Compass
business, including any joint venturecompanies or consortia that are underCompass’ day to day control or are
majority owned, and all Business
Partners working or representing any
Compass business anywhere in theWorld.

3.2

Anyone who has concerns orinformation relating to misconduct thatgive rise to a potential or actual breachof our CoBC may raise such concerns
under this policy. This includes but is notbreaches of our Code of Business Conduct, standards, policies andprocedures; illegal conduct, such as theft, dealing in, or use of illicit
drugs, violence or threatened violence, or criminal damage against
property; fraud, money laundering, terrorist financing, tax evasion or
misappropriation of funds; offering, giving or accepting a bribe;
conflicts of interest; financial irregularities including false accounting,financial misstatements and misrepresentations; conduct causing

1

limited to current and former
employees, contractors, suppliers,
service providers, trainees, joint venture
partners, members of the communities
in which we operate, and also theirpartners, dependants and relatives.
3.3

Compass will respect and comply with allapplicable local laws. In the event that
local laws have stricter or specificrequirements including reporting party
rights and protections, concern handling,
investigations and other applicableobligations for any Compass business, acountry based policy should be
implemented by management by way of
a local addendum to this Group Policy.
Group Ethics & Integrity should be
notified in such circumstances.

4

Policy Requirements: Our Duty andRight to Raise Concerns

4.1

Asking questions, being curious andreporting known or suspected
misconduct or improper circumstancesor behaviours benefits and protects all ofus. 1 We all have a shared duty andindividual right to report concerns thatcircumstances inconsistent with our
CoBC are being contemplated,occurring, or may have occurred, using
our Speak Up resources.

danger to people, the environment or the financial system; sexual
harassment, discrimination, bullying or harassment; human rights
issues such as modern slavery, child exploitation or the infringementof indigenous peoples' rights; and failure to comply with, or breachof, legal or regulatory requirements including disclosure obligations.

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4.2

4.3

4.4

You are not expected or required tohave absolute proof of misconduct or
improper circumstances in order to raisea concern.
You should be led by your instincts andshould provide as much information as
possible when raising your concern
about how this has arisen. We are here
to support our people in doing the rightthing. To that end, you will not face any
form of disciplinary action or detriment
in respect of a concern raised in goodfaith that is later found to be mistaken or
unfounded (see Section 10).

•

•

6

Compass Group Speak Up Resources

6.1

For queries about or suspected breachesof our CoBC, tell someone you trust by
speaking to:Just as it is an expectation that any
concerns be promptly reported,
Compass also strives to assess andresolve all concerns in a timely manner.
Any delays will be communicated to theappropriately involved parties. For those
who feel comfortable, routinely
following up on your concern will help
to avoid any delays.

5

Getting the Right Help

5.1

We want to help everyone find the righthelp and support for their concerns or
issues as quickly and efficiently as
possible. Where your concern does not
relate to a possible breach of our CoBC
or concerns regarding any unethical,
illegal, or other improper circumstancesor behaviours you should use thefollowing resources:

For operational Health, Safety &Environmental issues, contact yourlocal HSE manager; or
For concerns relating to your own
employment position or circumstances
at work including grievances 2 that do
not relate to a possible breach of our
CoBC we encourage you to raise theseconcerns directly with your manager,
your unit manager, or your local HR
team.

•
•
•
•
•

your manager or unit manager;
your local HR manager (“HR”) or Listen
Up Champion (“LUC”);
a member of your country, Regional orGroup legal team (“Legal”);
a member of Group Ethics & Integrity(“E&I”); or
Raise your concern through the Speak
Up platform.

6.2

For those of you that are not online orprefer to report via telephone, dedicatedcountry phone numbers for the Helpline
are available on our Ethics & Integrity
portal and are displayed on posters
throughout Compass’ workplaces andpremises.

6.3

Reports received by and raised directly
to management about suspected
breaches of our CoBC must be referredto the country or regional Listen Up

2
Examples of grievance may include interpersonal conflict with yourmanager or another colleague or challenges to reviews in relation to
performance, promotion, work arrangements or disciplinary action.

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in regularly or to engage directly, if you
feel comfortable doing so, with theindividual assigned to follow up on yourconcern.

Champion and/or General Counsel and,in turn, will be assessed and entered into
the Speak Up systems, as required.
7

Making a Report

7.1

If you become aware, or have reason tosuspect, that unethical, illegal or otherimproper circumstances or behaviours
connected to Compass arecontemplated, occurring, or may haveoccurred, you are strongly encouraged
to raise your concerns in a timely
manner.

7.2

When you voice your concerns, you
should provide as much information
about the issue as you can to help
address the concern effectively.
including but not limited to:
•
•

•

7.3

background, context, history andreason for the concern;
dates, places and, if possible, names or
identifying details of those involved;
andany documents, files or references that
may be relevant to the situation or you
think would help Compass look into
the issues. If you do not have all thesedetails, do not let this hold you backfrom raising your concerns andproviding additional details later.
We understand and respect that somepeople feel more comfortable notdisclosing their identity, so you canreport concerns anonymously andremain anonymous if you wish. We ask
everyone who chooses to use the Speak
Up platform or helpline to take note of
their reference number and check back

7.4

The diagram below sets out the key
steps that will occur when you voice
your concerns under this policy.

8

Investigation

8.1

If appropriate, your report will beallocated for investigation. Investigations
will be conducted respectfully,
impartially and fairly, including affordingthese principles, rights and applicableprivileges to the people mentioned inyour report. From time to time, we may
engage an external independent third
party to lead or support an internal
investigation or review of circumstances.

8.2

If you have provided contact details
and/or are contactable anonymously
through the Speak Up platform or
helpline two-way messaging facilities,
you will receive an acknowledgment thatyour report has been received and will
be updated if your case is allocated forPage 4 of 7

including whether you wish to provide
your personal identification details or
remain anonymous. Our Compass Speak
Up platform and helpline is operated byan independent third-party provider andis available 365 days a year, 7 days aweek, 24 hours a day, in all of thecountries in which we operate. Reports
received are referred to Group Ethics &Integrity for confidential review andassignment for follow up and/or
investigation, as appropriate.

investigation or follow-up.
8.3

You may be asked to confidentiallyparticipate in the investigation bycontinuing to provide information or
additional details as needed. We will
endeavour to provide you withappropriate progress updates, asnecessary, and you will be informed
when the case is ready to close andprovided feedback on the outcome,subject to legal, privacy, andconfidentiality considerations.

8.4

In raising concerns in good faith, you are
expected to cooperate with all
investigations by providing honest,
truthful and complete information. If you
are found to have been personallyinvolved in misconduct including abreach of our CoBC or other policies,
standards and procedures, reporting it
will not absolve you from accountability– but your cooperation with theinvestigation will be considered as partof any decision that Compass makes.

8.5

Compass strives to resolve all mattersinternally but nothing in this policy
should be interpreted to prohibit you
from reporting, at any time, suspectedunlawful conduct to any relevant
governmental authority, regulator orother external party.

9

Confidentiality

9.1

Compass will seek to protect theconfidentiality of any person making areport under this policy. Reports may besubmitted using our Speak Up resourcesin way you feel most comfortable with,

9.2

Bear in mind that it may be helpful for
you to identify yourself so that you canbe contacted for additional informationthat may assist with following up yourconcern. If, however, you feel that you
are not comfortable disclosing youridentity, anonymous reports should
contain sufficiently detailed information
to enable us to effectively follow up on
and address the reported concern.

9.3

If you receive any information about any
report and related investigation you
must treat this as confidential.

9.4

Your identity will not be disclosed
without your consent to anyone beyond
those dealing with and investigating theconcerns or those included on a strictneed-to-know basis to receive and act
upon the findings or remedial actions,
unless this is necessary andproportionate in the context of looking
into the matter, undertaking an
investigation and/or seeking legal
advice.

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10 Protection from Retaliation
10.1 Compass strictly prohibits and does nottolerate retaliation or detrimental
conduct in response to you raising a
concern or being able to raise a concern.
10.2 Compass will protect you from being
retaliated against or being subjected todetrimental conduct, having the ability
to, contemplating or in fact raisingconcerns in good faith or incircumstances in which issues raised inyour report turn out to be mistaken or
unfounded.
10.3 Amongst other measures that are
deemed appropriate we can provide youwith details of available employee
support services and engage with HR orother functional partners (unlessconflicted) if concerns about your healthand wellbeing arise.
10.4 Protection against detrimental conduct
or retaliation also applies to individuals
conducting, assisting or participating in
an investigation under this policy.
10.5 If you believe you have been subjected
to any form of retaliation or detrimental
conduct as a result of contemplating
making a report, having raised a concern
or assisting in any investigation, or you
witness retaliation against someone else,
you should use the Compass Speak Up
resources (set out in paragraph 6) toreport it.

10.6 We follow up with everyone who raises a
concern using the Speak Up platform or
helpline to check whether they believe
they have suffered any form of
retaliation.
11 Compliance with this policy
11.1 Anyone who is found to have breachedthis policy by neglecting to report orescalate a breach or suspected breach of
our CoBC to our Speak Up resources
without good reason, or by retaliating or
being party to retaliatory conductagainst any person within the scope of
this policy, may be subject to disciplinary
action. In the case of Business Partners,
this may include but may not be limited
to termination of any relationship with
Compass.
11.2 In addition, any person who is found tohave intentionally made a false
allegation, provided false or misleading
information in the course of an internal
review or investigation or is otherwise
found to have acted in bad faith may besubject to disciplinary action.
12

Monitoring and Review

12.1 The Group Head of Ethics & Integrity willlead a review of this policy on an annual
basis, taking into consideration its scope,
efficiency and effectiveness, changes torelevant laws and management
information collected regarding SpeakUp reports and investigations.

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12.2 The Group Head of Ethics & Integrity willreport on their review of the policy andthe effectiveness of the Speak Up
programme in accordance with theterms of reference governing Compass
Group PLC’s Corporate Responsibility
and Audit Committees, respectively.
Compass Group PLC’s Corporate
Responsibility Committee will approve
any suggested amendments to thispolicy, as appropriate.
12.3 You are invited to comment on thispolicy and suggest ways in which it
might be improved. Comments,suggestions and queries should be
addressed via the Group Ethics &Integrity portal using the ask a question
facility.

12.4 Any exceptions to this policy requireapproval from the Group Head of Ethics& Integrity.
13 Records and Privacy
13.1 Compass Group cares about yourprivacy and will retain records, as part ofthe confidential Speak Up, We’re
Listening programme, in compliancewith applicable data protection andretention guidelines.
14

Miscellaneous

14.1 This policy does not form part of any
Compass personnel's contract of
employment and we may amend thepolicy at any time.

This policy has been approved by the Compass Group Plc Executive Committee and
Board of Directors.

Dominic BlakemoreGroup Chief Executive

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