Speak Up Channel
Code of Ethics and Business Conduct (CEBC)
The Speak-Up Reporting channel is to safely submit an inquiry or report possible misconduct regarding any potential violation of law, regulation or any Amadeus policy related to business practices or ethical conduct – such as the Amadeus Code of Ethics and Business Conduct (CEBC).
What are the Speak Up Policy and reporting channel?
All communications received may be reported without fear of retaliation against anyone that reports issues in good faith and is governed by the Speak-Up Policy, found here.
The Speak Up reporting channel exists to ensure:
- Amadeus employees, former employees, customers, suppliers, business partners and any third parties can safely report any suspected instances about our business practices and/or ethical conduct which would result in a breach of applicable law and/or policy; and
- the protection of the confidentiality and identity of a Reporting Party.
The Speak Up reporting channel is an external tool, hosted outside of Amadeus ensuring that maximum confidentiality, security and privacy standards are applied. The platform guarantees the confidentiality of the Reporting Party, the incidents reported, and the people mentioned or involved. The information is encrypted and stored in a secure environment. A Reporting Party can use the Speak Up Reporting channel to make a report anonymously, while allowing completely anonymous interaction with the team receiving and reviewing the report, through a “secure inbox” which is mandatory at the time of filing their report.
What can I report?
The Speak Up Reporting channel is intended for reports of any suspected instances about our business practices and/or ethical conduct which would result in a breach of applicable law and/or policy.
The different situations that can be reported include concerns relating to the following:
- Workplace Harassment
- Sexual Harassment
- Discrimination
- Other labour conflicts
- Violation of Privacy
- Security Provisions or policies
- Violation of corporate tax laws
- Conflicts of Interest
- Corruption
- Bribery
- Violation of the CEBC
- Violation of other Internal Policies or Procedures
- Intellectual Property Violations
- Contractual clauses
- Fraud
- Accounting irregularities
- Non-compliance with regulations and legislation
- Money Laundering and Terrorist Financing
- Payments Regulations Violations
- Customer Protection Violations
- Market Abuse/Insider Trading
- Violation of competition or anti-trust laws
- Trade or Economic Sanctions
- Non-Compliance with ESG Guidelines
- Inquiry / I am looking for advice
Is the Speak-Up Channel intended for customer complaints or general inquiries?
The Speak-Up Reporting channel is not intended to apply to personal work-related grievances regarding employment such as decisions relating to the terms and conditions of employment, suspension, termination or performance evaluations. For customers, suppliers, business partners and third parties, the Speak-Up Reporting channel would not apply to commercial dissatisfaction arising from a contract nor general inquires such as issues with refunds, training, tickets, etc. For general inquiries and customer complaints, please go here.
What is the process for submitting a report? What is a secured postbox and how do I set up one?
To submit an anonymous or personalized report, start by clicking the “Submit a report“ tile at the middle of the Speak Up page.
There are 5 steps to the report process:
- First, you will be asked to select which country the incident occurred.
- Next, you will answer questions about the incident and in your own words elaborate on your report
- You will have the choice to report anonymously or provide your name. and email address. If you choose to report anonymously, we encourage you to provide an email address. Your email address is used solely for notification purposes. Amadeus will not have access to it.
- You will be asked to create a password for your secure inbox. The secure inbox is mandatory and will allow us to enable communication with you, assist in the investigation process, and provide updates on your report.
If you already have a secure inbox, you can access it directly via the Secure Inbox tile . You will have to enter the Case ID you were provided when you submitted your report and the password you provided when creating your Secure Inbox.
- Lastly, you will be asked to enter the characters displayed in the Security validation section.
You will receive confirmation that your report has been submitted along with Your Case ID: Please record your Case ID as it is required to access your Secure Inbox.
As long as you do not enter any data from which conclusions about your person can be drawn, the technology of the Incident Reporting tool will protect your anonymity.
How do I receive feedback and remain anonymous at the same time?
The overriding principle of the Speak Up Reporting in use is the protection of the whistleblower. The system’s anonymity privacy function is certified by an independent body.
When setting up your secure inbox, please select your own password. If you lose your login details, submit a new report. (For security reasons and protection of your anonymity, we cannot recover your login credentials) . As this will be a new secure inbox, you cannot see the content of your previous report.
Your report is kept anonymous through encryption and other special security routines. If you want to submit your report anonymously, you do not have to provide any personal details, however we strongly encourage you to provide an email address for notification purposes only. Amadeus will not have access to it. Do not submit any information that can be traced back to you. Please do not use any technical device, for example a PC or smartphone, that has been provided by your employer, to submit your report.
Via the secure inbox, an examiner will provide you with feedback on what is happening with your information or pose questions if details still need to be clarified - you will also remain anonymous during the dialogue. We are interested in reports to avoid damages, not in you as a whistleblower.
What happens after a report is made?
Depending on the nature and extent of the report, it may:
- Be investigated by Amadeus;
- Be referred to an external party such as a law firm or a consultant;
- Be referred to the police or to a regulatory or enforcement agency.
Following the filing of a report, and to the extent it will not compromise the investigation, a Reporting Party will be informed about
- the status of the ongoing investigations,
- the outcome of the investigation; and
- information on support mechanisms available if requested. The extent and frequency of the information made available to a Reporting Party will depend on the nature of the issue that has been reported.
A Reporting Party may be requested to make a statement to the relevant law enforcement authority(ies) or otherwise give evidence to the extent required by law or order of a court. If, at the conclusion of an investigation, Amadeus determines that a violation has occurred, Amadeus will take appropriate disciplinary or legal action against the violator(s) depending on the seriousness of the issue detected.
I have reported a concern, but have not heard anything back
A secure inbox is required at the time of your report to provide an acknowledgement of receipt within 7 days.
Even if you choose to remain anonymous, you must create a secure inbox. This is required to enable communication with you, assist in the investigation process, and provide updates on your report.
If you reported the issue to a line manager, we would advise that you escalate this to the Global Head of Corporate Compliance.
I received acknowledgement of receipt of my report, when should I expect to be provided updates?
Amadeus will provide feedback within 3 months (that is, what, if any, action will be taken by Amadeus, to assess the accuracy of the allegations made in the report and how the issue will be reported, including but not limited to actions such as an internal inquiry, an investigation, prosecution, or the closure of the procedure).