Romania Whistleblowing Policy | Legal Info | Hootsuite

·Whistleblowing Policy for Hootsuite SRL

·Last updated: December 22nd, 2023

·Hootsuite is committed to carrying out our business in a safe, honest, and ethical way. Part of that is creating an open and supportive working environment where people feel able to speak up about any suspected wrongdoing. The Hootsuite Whistleblowing Policy for Romania details our process for dealing with whistleblowing. It applies to all our Romanian employees and those Hootsuite SRL collaborators falling within the scope of the Romanian whistleblowing law.

·For more information on whistleblowing, including what it is and what protection is provided, please refer to the Hootsuite Whistleblowing Policy available here.

·Some points to remember:

• ·This is a Romania specific policy. The Hootsuite Whistleblowing Policy ("Policy") only applies to employees and collaborators of Hootsuite SRL, as required pursuant to Romanian whistleblowing law. If you are an employee of, or collaborate with, any other Hootsuite entity, the Policy does not apply to you.
• ·You must act in good faith. You don't need to have any proof that something is happening. As long as you have reasonable grounds to believe, given the circumstances and the information available to you at the time of reporting, that the matters you report are true, you should report your concerns. But if we find that you've knowingly made a false allegation, we may deal with this under our disciplinary procedure.
• ·Personal grievances are not in scope. If you've got a personal complaint or concern, like about how you're being treated at work, this isn't a whistleblowing matter. It would be covered under our Respectful Workplace Guidelines, so please refer to these instead. You can also call our Employee Assistance Programme.

·Blowing the whistle

·If you need to raise a concern, here's how you can go about doing it:

• ·Your manager (if you are a Hootsuite employee)

·Contact your manager, someone else in your reporting chain, or any other manager outside of your reporting chain. Other reporting channels

·If you feel that you can't raise your concern with your manager, or if you have but you've still got concerns, you can submit a concern through the webform located below.

·Your report needs to include what your concern is, why you think it's true and any other details you can give us. Remember to include your contact details. We may need to get in touch to talk about your concerns or to get some more details.

·You can raise your concerns anonymously if you like and we'll take these seriously. But it may be difficult for us to do a proper investigation if we can't talk to you about other information we might need. External reporting

·If you have reasonable grounds to believe that there is a risk of retaliation against you or a low chance of the matter being effectively remedied by Hootsuite, then you do have the option of reporting the matter to a relevant public authority or institution with expertise in the subject matter of the concerns you have raised.

·The National Agency for Integrity is the authority with general competencies in relation to external whistleblowing reporting. Further information on how you can report a concern externally according to the Policy can be found on the website of the National Agency for Integrity, respectively on: Informații generale - Avertizori în interes public (integritate.eu) Public disclosure

·Public disclosures are disclosures to the media, professional organizations, trade union, non-governmental organizations, parliamentary committees.

·Although not prohibited, Hootsuite's view is that it will very rarely, if ever, be appropriate to raise a whistleblowing concern directly to the media.

·If you choose to publicly disclose information regarding a violation of the law, you may only benefit from protection afforded under Romanian whistleblowing law if one of the following conditions is met:

• ·You first reported internally and externally or directly externally but consider that appropriate measures were not applied within the term provided by law; or
• ·You have good reasons to consider that:
• ·the violation may constitute an imminent or obvious danger to the public interest or the risk of irreparable damage; or
• ·in the case of external reporting there is a risk of retaliation or a low probability that the violation will be effectively remedied given the specific circumstances of the reporting.

·Hootsuite's designated whistleblowing team

·Access to reports received through our reporting channel is restricted to appointed individuals at Hootsuite with the authority to handle whistleblowing cases. Their actions are logged, and handling is confidential. The Hootsuite legal team (located in Canada and the United Kingdom) is the designated department dealing with reports. When needed, individuals who can add expertise may be included in the investigation process. These individuals can access relevant data and are also bound to confidentiality.

·Report a concern

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