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Our Whistleblowing Framework

Inchcape strives to comply not just with the letter of the law in all of the countries in which we operate, but also within the spirit. Our commitment helps to build trust, protect our reputation, and secure our future. Importantly, it also helps to protect the reputation of our automotive partners of whose brand equity we are custodians.

Doing the right thing ensures we do not compromise ourselves or Inchcape by our actions, and that we are aware of the risks we face as a global business. There may however be times that our employees, strategic partners, our contractors and our third parties feel that the right thing has not been done and, in these instances, it is important that we learn of potential misconduct, and address it. Inchcape’s whistleblowing process offers the opportunity for this to happen.

We must all show the courage to raise concerns and to challenge actions, decisions or behaviours that we believe to be wrong. We will not tolerate any retaliation or discrimination against anyone who raises or reports a concern in good faith and we guarantee the highest possible protection for whistle-blowers, persons implicated and those contributing to the investigation of misconduct.

Process

Employees or former employees, business partners, customers, or other third parties can submit reports if they have concerns relating to any forms of wrongdoing or concealing wrongdoing, including regulatory violations or misconduct.

We examine every report thoroughly and follow it up systematically. Our investigation process is conducted with utmost care and confidentiality and reports will be processed and stored in a secure, data privacy compliant manner. Whistle-blowers will be protected from any form of retaliation.

 

Making a report

You are able to make a report using our independent reporting channel:

A confidential report can be filed using Ethics Point link: www.inchcape.ethicspoint.com.

Alternatively, a reporter can contact the Ethics Point reporting line by phone (UK):

0800 587 3804

QR code scanning

Reports can be submitted using the QR code below, and a reporter will be directed to the on-line platform for submission of the concern, attach the evidence and communicate via an online platform. This form of communication is confidential and protected. Whistle-blowers have the choice to provide their name or to remain anonymous. A confidential report can be filed using QR code:

Important note: should your preferred language not be listed, the report can also be submitted in any other language.

You can also make a report by e-mail, post and in person

A safe and secure way for whistle-blowers to speak up about misconduct can also be submitted by e-mail or regular mail in all languages.

Email: speakup@inchcape.com or ipom@inchcape.com

Postal address:

Inchcape plc

Group Internal Audit
22a St James Square
London
SW1Y 5LP
United Kingdom

In person

An in person report can be made at Inchcape operated dealerships or Inchcape office premises.

Inchcape Head office address:

22a St James Square, London SW1Y 5LP, United Kingdom

Whistleblowing Privacy Statement

Information on data protection

We would like to inform you about the collection, processing and use of personal data within the framework of the Whistleblowing Hotline.

If you provide your personal data via the Whistleblowing Hotline, Inchcape Plc and relevant Inchcape Plc subsidiaries (hereinafter referred to as "we" or "Inchcape") will become the controller of your personal data. Detailed rules regarding the processing of personal data can be obtained by contacting Inchcape Plc (contact@inchcape.com) or Inchcape Plc subsidiaries.

Using the Whistleblowing Hotline is voluntary, if you place a report via the hotline, we’ll collect the following personal data and information:

  • Your name (if you disclose your identity),
  • Your contact details (if you provide them),
  • The fact that you have placed the report via the hotline,
  • Your work-related context with Inchcape (if you provide such information),
  • Names of persons and other personal data of the persons you mention in report (if applicable).

Purposes for processing personal data

The Whistleblowing Hotline receives and processes any reports of violations of the Code of Conduct, breaches of legal and regulatory requirements and other matters related to unethical or unlawful behavior which has been noted in a work-related context, in a secure and confidential environment.

In the context of the whistleblowing tool, personal data is processed for the purpose of the initial reporting and investigation of reports of the alleged breaches stated above and the subsequent review of these reports and follow-up.

Legal grounds for processing personal data

In the context of the whistleblowing tool, we will mainly process your personal data based one of the following legal grounds:

  • Because it is necessary to comply with a legal obligation, given the fact that whistleblowing systems are mandatory in some countries where Inchcape is located.
  • For the purposes of our legitimate interests, more specifically to monitor compliance with our Code of Conduct. In this respect, we will always determine case by case whether our interests are not overridden by the interests, fundamental rights and freedoms of the data subjects involved.

If we have the legal obligation to obtain your free, informed, specific, and unambiguous consent to process your personal data for certain purposes, we will only process your data for such purposes to the extent that we have obtained such consent from you.

Data retention period

Personal data is stored for as long as the clarification and final assessment requires it, or if a legitimate interest of the company exists or if this is required by law. After that, this data is deleted in accordance with legal requirements. The duration of retention depends in particular on the severity of the suspicion and the reported possible breach of duty.

Data recipients

Your personal data also will be disclosed to the NAVEX Global, Inc. (Whistleblowing Hotline provider for Inchcape), Inchcape’s employees and associates and entities to whom we have entrusted the processing of your personal data.

Rights of the data subject

We assure that all persons whose personal data is processed by Inchcape are entitled to the appropriate rights resulting from the data protection law, you and the persons mentioned in the report have the right of access, rectification, erasure, restriction of processing as well as a right to object to the processing of your personal data and, in certain cases, the right to data transferability. Your personal data will not be used for profiling or for making automated decisions concerning you.

Confidentiality and disclosure to third parties

The information you provide will be sent to us via the Whistleblowing Hotline on a totally confidential and anonymous basis if you should choose.

In the course of processing a report or as part of an investigation, it may be necessary to pass on information to other employees of Inchcape Plc or subsidiaries of Inchcape Plc and their employees, e.g. if the information relates to events which occurred in subsidiaries of  Inchcape Plc. Any person who is given access to the data is obliged to maintain confidentiality.

As part of this procedure, Inchcape can contact the persons indicated in the report (as long as they do not remain anonymous) and will inform them of the results of the investigation. You have our guarantee that your comments will be heard.

If necessary, for clarification purposes, information may be forwarded to subsidiaries of Inchcape Plc in a country outside the European Union or the European Economic Area based on the suitable or appropriate data protection guarantees in order to protect those concerned. We always ensure that the relevant data protection regulations are observed when passing on information.