Air France Integrity Line
Air France has set up a system for collecting and processing alerts accessible to all its employees and its stakeholders (contractors, suppliers, subcontractors, communities, etc.) in accordance with Law No. 2016-1691 of December 9, 2016 relating to transparency, the fight against corruption and the modernization of economic life (known as “Sapin II”), Law No. 2017-399 of March 27, 2017 relating to the duty of vigilance of parent companies for their controlled entities and ordering companies for their suppliers, and any action on the protection of whistleblowers and other persons falling under the scope of such laws.
Transparency and trust are at the heart of our corporate culture and essential for the effective implementation of the Air France-KLM Principles (the “Principles”). In this respect, we therefore encourage all our employees, as well as our stakeholders, to inform us of any information relating to violations, or potential violations, of the applicable laws and regulations or, more generally, to situations contrary to our values and our internal rules.
Who can file a report?
The Integrity Line is intended for all Air France employees and stakeholders regardless of their location, particularly:
- employees, former employees and job applicants (when the information provided was obtained as part of their application)
- external and occasional employees (eg trainees, apprentices, temporary workers, etc.)
- contracting parties and other stakeholders: customers, service providers, suppliers, subcontractors, etc.
The whistleblower must provide, at the same time as the report, any element or information to confirm that he/she belongs to one of the categories of persons referred to above.
The whistleblower must act in good faith, i.e. having reasonable grounds to believe, in the light of the circumstances and the information available to him/her at the time of the report, that the facts he/she reports are true.
Misuse of the Integrity Line, i.e. use in bad faith or with the intention of harming others, may lead, where appropriate, to legal proceedings against the whistleblower.
The whistleblower must act without direct financial compensation. The reporting process must not give rise to a reward or remuneration of a financial nature. For example, the whistleblower should not seek financial incentive in exchange for reporting or condition the communication of information to the payment of a sum of money.
What types of acts or behavior can be reported?
Any breach of the Principles and other internal rules applicable within the Air France-KLM Group and/or Air France, any violation of national and/or international laws and regulations and in particular any situation related to the following areas:
- Accounting / Financial Fraud
- Acts of corruption or influence peddling
- Anti-competitive practices
- Infringement of fundamental freedoms and human rights, of people’s health or safety
- Non-compliance with environmental norms and standards
- Fraudulent use of personal data
- Any other crime, misdemeanor, threat or serious harm caused to the general interest.
How to report a file?
The Air France – KLM Group has set up a digital reporting system allowing confidential and anonymous reports to be made, if necessary, directly accessible via this link: https://integrity.airfranceklm.com/.
This system is available 7 days a week, 24 hours a day, in 11 languages and allows reports to be made to the Group entities which have implemented the Integrity ine.
For Air France, the whistleblower must select « Air France » in the first input screen.
After submitting the report via the online tool, the whistleblower receives an acknowledgment of receipt within a maximum of 7 working days indicating that the report will be the subject of an in-depth examination. The whistleblower is informed of the various stages of processing his/her report through the secure space made available to him/her.
If a report is issued anonymously, i.e. without identifying its author or, for example, by providing a name that does not correspond to the true identity of its author, Air France is not required to acknowledge receipt of the report and inform the whistleblower of the various processing steps. In this case, it is up to the whistleblower to contact Air France to follow up on his/her alert.
Anonymous reports are processed only if the seriousness of the facts mentioned is established and the factual elements communicated by the whistleblower are sufficiently detailed.
Finally, the whistleblower has the possibility of carrying out, either directly, or after having filed a report via the online tool, an external report to the authorities whose list has been defined by “Decree n° 2022-1284 of the 3 October 2022 relating to the procedures for collecting and processing reports issued by whistleblowers”.
How are reports handled?
Air France has designated dedicated, impartial and trained employees internally in charge of receiving and processing the reports received via the online tool. These case managers examine the content of the reports submitted, verify that they meet the acceptability criteria, and can contact the whistleblowers in order to clarify the information reported, if necessary, and/or to inform them of the follow-up given to the processing of their alerts.
The corresponding information is communicated to the Air France Compliance & Ethics Committee, which decides on the follow-up to be given, conducts internal investigations, if necessary, and ensures that reports are processed and closed.
The online tool and the internal procedure for processing reports guarantee strict confidentiality with regard to:
- the identity of whistleblowers
- the identity of the persons targeted by the whistleblowers and, where applicable, of any other third party mentioned in the report
- information collected by all the recipients of the report.
Processing of personal data
The processing of personal data is carried out in compliance with the applicable regulations, in particular the provisions of Law No. 78-17 of January 6, 1978 relating to data processing, files and freedoms and Regulation (EU) 2016 /679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data or “GDPR”.
Protection of whistleblowers
The whistleblower acting in good faith and without seeking any direct financial compensation is entitled to the protection measures provided for by law, in particular the absence of any form of retaliation. If the whistleblower thinks he/she has been subject to such a measure following the submission of his/her report, he/she must immediately inform Air France of this through the online tool.
The following persons are also entitled to protection:
- Facilitators – any natural person or any private non-profit legal entity (eg. an association) who helps the whistleblower with his/her report
- People linked to the whistleblower:
- Individuals who risk being subject to retaliatory measures in the context of their personal or professional relationships (e.g. colleagues, relatives of the whistleblower, etc.);
- Legal entities, within the meaning of Article L. 233-3 of the French Commercial Code, belonging to the whistleblower, for which he works or with which he is linked in a professional context.