Last updated: June 2024

      Report a Concern 

      Averna is committed to fostering a culture of reliability and accountability in the workplace as well as with others. If you see something, whether you are an employee or a business partner, you have the right and the responsibility to say something. 

      Whistleblowing focuses on the disclosure of misconduct in the interest of the public and organizational integrity. Grievances (or complaints), on the other hand, are generally focused on resolving individual or interpersonal issues within the workplace environment. Our whistleblowing and grievance mechanisms are also governed by, and form an integral part of, our policy on preventing and dealing with psychological harassment and sexual violence in the workplace.

      Both processes are crucial to for maintaining transparency, accountability, and fairness within organizations.

      Contact Points

      You can reach out to us using the table below:

      Concern or issue Contact point
      General legal@averna.com
      Data privacy privacy@averna.com 
      Legal compliance & ESG compliance@averna.com 
        Harassment or sexual violence   hr@averna.com

       

       In addition to our internal whistleblowing and grievance procedure, Averna has also created a communication channel to enable employees to raise issues even when they are uncomfortable with reporting them locally or if they fear retaliation. You may submit such issues to our Chairman of the Board, who is independent from Averna’s management, by sending an e-mail to ethics@averna.com. This channel is anonymous from Averna’s perspective.

      Ultimately, no matter who you reach out to, the same rule applies: your report will be treated seriously, discreetly, and with the utmost respect for your confidentiality and well-being, just like we will all protect you against retaliation.

      Averna does not take reprisals lightly – any colleague who engages or participates in retaliation and/or who discourages another colleague from reporting or seeking help will face disciplinary action.

      Reporting About a Colleague

      We understand and appreciate your concern for your colleagues' well-being. We strive to address legal or compliance issues with genuine consideration of their impact on the individual, which is why we will always focus on bridging legal and compliance gaps, and not on assigning blame. We are here to help and guide, not to police or shame

      You help us ensure that Averna operates ethically and responsibly – we commit to reciprocating this sense of ethics and responsibility when handling your reports. You trust us and we trust you.

      Structure of the Whistleblowing and Grievance Process 

      The receipt of your whistleblowing or grievance by the contact point you have chosen triggers a diligent process that puts emphasis on careful and secure documentation, tactful communication with the relevant parties, and appropriate follow-up actions to address the issue and prevent recurrence.

      In general, you can expect the following steps to take place after submitting a complaint:
      1.    Within 24 hours of submission, you will receive an acknowledgment of your complaint via encrypted e-mail.
      2.    Within 72 hours after acknowledgement, your complaint will be confidentially transferred to the employees who are relevant to evaluating and investigating the complaint on an “absolutely need to be informed” basis. Except in situations where we have a legal or operational obligation to disclose your identity, your complaint will remain anonymous throughout the transfer.
      3.    After a diligent assessment of your complaint and the matters it pertains to, we will develop an adequate resolution plan with your collaboration. The plan will be submitted to you within a maximum delay of three (3) months.
      4.    If you accept the resolution plan, we will proceed with its implementation in a way that respects your privacy and that does not allow you to be identified. 
      5.    During and after the implementation of the resolution plan, we will ensure continuous monitoring and follow-ups as necessary.
      6.    Finally, if required by the nature of your complaint or flagged risks, we will put in place the proper company-wide mechanisms (such as targeted training or new policies) to prevent or limit the possibility of its recurrence.

      Steps 3 to 5 may each take anywhere between a few days and a few weeks to be completed depending on the nature of the complaint and its scope, while step 6 may require up to a few months, depending on the mechanism implemented. In all cases, your grievance will remain high on our list of priorities. 

      At any point during the process, you should feel entirely comfortable bringing up any additional issues or concerns you might have. Please note, however, that doing so may impact the timeline of the process.

      Appealing a Resolution Plan

      If you do not accept our proposed resolution plan, you have the possibility to appeal it by communicating your refusal to us through the communication channel used throughout the grievance process. An appeal will immediately trigger a review of the resolution plan, in which case we will work together until we reach an alternative that is satisfactory to all of us.

      Appealing a resolution plan may increase the processing time of your complaint.

      Complaint Withdrawal

      While we strive to do our best to adapt our resolution approach to the context of your grievance and to accommodate your needs throughout the process, it may not be feasible or appropriate to withdraw your complaint due to the seriousness or significance of the issue raised. 

      Before reporting or whistleblowing, please keep in mind that once a complaint is made, it may need to be addressed or investigated regardless of any subsequent change of mind or desire to retract it, especially if it involves matters of legal or ethical importance.

      Evaluation and Continuous Improvement

      Our whistleblowing and grievance process is subject to evaluations at least once every 12 months and on an ad hoc basis. This responsibility is shared by our legal team, relevant executives, and Board of Directors.

      Evaluations focus on the aspects and metrics identified in the table below, which is not exhaustive. 

      Aspects Metrics
      Timeliness

      • Average time taken to acknowledge receipt of a grievance or whistleblower report.

      • Average time taken to investigate and resolve grievances or whistleblower reports.

      • Percentage of grievances or reports addressed within established timelines.
      Fairness and objectivity

      • Number of grievances or reports resolved in favor of the complainant.

      • Number of grievances or reports resolved through mediation or arbitration.

      • Percentage of grievances or reports where the investigation process was perceived as fair by all parties involved.

      Quality of resolution

      • Percentage of grievances or reports that result in satisfactory outcomes for all parties involved.

      • Rate of recurrence of similar grievances or reports after resolution.

      • Feedback from employees on the effectiveness of the resolution process.
      Confidentiality and anonymity

      • Measures taken to protect the confidentiality of whistleblowers and complainants.

      • Feedback from whistleblowers and complainants on their confidence in the confidentiality of the process.
      Employee satisfaction and trust

      • Employee survey results related to their perception of the organization's commitment to addressing grievances and whistleblowing.

      • Trust levels in the organization's leadership and HR department regarding handling grievances and whistleblowing.

      • Employee turnover rates and correlations with grievances or whistleblowing incidents.

      Legal compliance

      • Number of grievances or reports related to legal violations or compliance issues.

      • Percentage of grievances or reports where legal requirements for reporting and investigation were met.

      • Outcome of legal actions or settlements resulting from grievances or whistleblowing incidents.

      Training and awareness

      • Percentage of employees who are aware of the grievance and whistleblowing policies and procedures.

      • Frequency and effectiveness of training programs on grievance handling and whistleblowing.

      • Feedback from employees on the accessibility and clarity of the grievance and whistleblowing policies.