Policy
Speak-Up and Remediation Procedure
1. Purpose and who can use it
This procedure is how anyone raises a concern about the conduct of Chronotope Labs, Inc. ("Chronotope"), its people or its suppliers, how we look into it, and how we put things right when our activities have harmed someone. It is open to everyone: employees, contractors, interns and advisors; candidates; suppliers and their workers; employees of our clients and partners; and people in the communities near the sites where we work. It is available in English and Spanish.
2. What to report
Any suspected violation of our policies or the law, including:
- Discrimination, harassment, bullying or retaliation.
- Child labor, forced labor, human trafficking or unsafe working conditions, at Chronotope or at a supplier.
- Unsafe situations at a client site involving our people.
- Bribery, fraud, conflicts of interest or falsified records.
- Misuse of confidential or personal data.
- Any other conduct that harms a person's rights, health or dignity.
You do not need proof. A reasonable, good-faith belief that something is wrong is enough.
3. How to report
Use whichever channel you are comfortable with:
- The Chief Executive Officer, in person, by message or by email to [email protected].
- An independent channel, for concerns that involve the Chief Executive Officer or when you prefer not to go through management: the company's outside counsel, Orrick, Herrington & Sutcliffe LLP, which receives reports on Chronotope's behalf, independently of management, and relays them without identifying the reporter if asked. Write to the firm for the attention of the partner responsible for Chronotope Labs, Inc.; its offices and contact details are published at orrick.com.
- Anonymously, through either channel. An anonymous report is handled the same way; it only limits our ability to ask follow-up questions and to tell you the outcome.
A report can be made in English or Spanish, at any time, and there is no deadline for reporting.
4. How we handle a report
- Acknowledgement. Within two business days we confirm that the report was received and who is handling it.
- Assessment. Within ten business days we decide whether the facts, if true, would breach a policy or the law, and whether an investigation is needed or the matter can be resolved directly. If the report involves the Chief Executive Officer, outside counsel decides and appoints an independent person to handle it.
- Investigation. An impartial person with no involvement in the events gathers the facts: hears the person who reported and the person concerned, interviews witnesses and reviews records. Interim measures protect the reporter and anyone at risk while this happens.
- Conclusion. Investigations are concluded within 30 days of the assessment, or longer only where the complexity requires it, in which case the people involved are told why. The outcome and the actions decided are communicated to the reporter (where known) and to the person concerned.
- Follow-up. We check, after a reasonable period, that the actions were carried out and that the problem has not recurred or turned into retaliation.
5. Prevention
We would rather prevent harm than remedy it. Before taking on a new client site, a new country or a new category of supplier, we consider what human-rights risks the work could create or contribute to, including for the host site's workers and nearby communities, and how to avoid them. Our policies are explained to everyone on joining and refreshed every year, suppliers accept our Supplier Code of Conduct, and the Chief Executive Officer reviews the reports received and the lessons from them at least once a year.
6. Remediation
If our activities, or those of a supplier working for us, have caused or contributed to a serious impact on the rights of a person or community, we put it right. Remediation is agreed with the people affected and, depending on the harm, may include stopping the activity, correcting the data or decision that caused it, a formal apology, restoration of a position or benefit, financial compensation for loss suffered, and changes to our practices so that it does not happen again. We do this without requiring the person to give up any legal right, we cooperate with any legitimate judicial or non-judicial process, and we document what was done. Where we are linked to a harm through a client or supplier without having caused it, we use our influence to have it remedied, and we reconsider the relationship if it is not.
7. Protection, confidentiality and records
Nobody suffers any adverse consequence for reporting in good faith, for supporting someone who reports, or for taking part in an investigation. Retaliation is a violation of our policies and is dealt with as misconduct, whoever commits it. A knowingly false report is also misconduct; an honest report that turns out to be unfounded is not.
The identity of the reporter and the content of the report are shared only with the people who need them to handle the matter, and the person concerned is treated as innocent until the facts are established. Records of reports, investigations and remediation are kept securely for at least five years, in a way that respects data-protection law, and are reviewed in aggregate once a year to improve this procedure.
The Chief Executive Officer owns this procedure; reports that concern the Chief Executive Officer are overseen by outside counsel.
Approved by Santiago Ampudia Castelazo, Chief Executive Officer, Chronotope Labs, Inc.