Syngenta Group EU Whistleblowing Policy

Important: Please carefully read this document and scroll down to Section 11 for your Country specific additional Whistleblowing information.

In compliance with EU Directive 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of EU law (“EU WB Directive”), Syngenta is to maintain internal reporting system available in each EU Member State where it is required by law.

1. How to submit a report?

There are two options to submit a report directly to Syngenta:

• Through Syngenta Compliance Helpline administered by Syngenta Group Compliance and available 24/7 in 24 languages. Please follow the link if you wish to submit a report using the Syngenta Compliance Helpline.
• Through the Internal Reporting Channel in your country (“Local Reporting Channel”) administered by an impartial EU Whistleblowing Local Channel Operator (“LCO”) in local language. You can submit the report in writing via email address below or verbally upon email request. You can request a face-to-face meeting with the LCO within a reasonable time notice*.

Please see below Local Reporting Channels Email Addresses. 

Internal reporting channels in Syngenta are designed, established, and operated securely and confidentially. Reporters may choose at their discretion which reporting channel to use and request the report to be investigated locally if they prefer.

2. What are internal reporting channels for? 

Internal reporting channels enable you to report unlawful or suspected corporate unlawful acts or omissions that you may have witnessed in connection with your present or former work-related activities. 

Who may report? All respective legal entity’s present, potential and former employees, including temporary and agency employees, trainees and volunteers, job candidates in active recruitment process with respective legal entity, persons that have ownership in the legal entity, or are members of its administrative, executive or supervisory body, persons working under the supervision and direction of contractors, subcontractors, and suppliers who learned about unlawful or suspected unlawful acts or omissions in work-related context (“Reporter(s)”). 

Please note that in each EU Member State, the list of violations eligible for protected reporting (“Whistleblowing Offences”) may differ in accordance with local laws. Please scroll down to Section 11 below for Whistleblowing Offences in your country. 

Based on the EU WB Directive as a minimum standard, offences in the following areas are Whistleblowing Offences in all EU countries:

(i) public procurement; 

(ii) financial services, products and markets, and prevention of money laundering and terrorist financing; 

(iii) product safety and compliance; 

(iv) transport safety; 

(v) protection of the environment; 

(vi) radiation protection and nuclear safety; 

(vii) food and feed safety, animal health and welfare; 

(viii) public health; 

(ix) consumer protection; 

(x) protection of privacy and personal data, and security of network and information systems (including the Digital Markets Act); 

(xi) breaches affecting the financial interests of the Union as referred to in Article 325 of the Treaty on the Functioning of the European Union and as further specified in relevant Union measures; 

(xii) breaches relating to the internal market, as referred to in Article 26(2) of the Treaty on the Functioning of the European Union, including breaches of Union competition and State aid rules, as well as breaches relating to the internal market in relation to acts which breach the rules of corporate tax or to arrangements the purpose of which is to obtain a tax advantage that defeats the object or purpose of the applicable corporate tax law. 

3. Is the Syngenta Compliance Helpline still available for reports of Syngenta Group Code of Conduct violations? 

Yes, the Syngenta Compliance Helpline remains available to receive reports of unethical behaviour or misconduct by Syngenta employees in violation of the Syngenta Group Code of Conduct.

4. Local Internal Reporting Channel Operators (“LCOs”). 

LCOs are to be appointed by the relevant country’s management as designated officers for operation of the local EU WB Channel.

LCOs have been given special responsibility and training in dealing with whistleblowing reports. 

They will: 

• treat the report confidentially unless otherwise required by law. 
• ensure the Reporter receives timely support to progress their report. 
• escalate to senior management any indications that the Reporter is being subjected to retaliation for raising their report. 
• remind the organisation of the need to give the Reporter timely feedback on how their report is being dealt with. 
• advise Syngenta employees that they have access to personal support through the confidential Employee Assistance Program whenever they feel they need it. 

Syngenta may outsource internal reporting channels to third party consultants. However, the responsibility to operate the internal reporting channel and to take the necessary follow-up steps, and to remediate the infringement, will stay with the respective legal entity.

5. Are there any designated authorities where you can submit EU WB Report? 

There are local competent authorities established in each EU Member State where you can alternatively submit an EU WB report.

However, in line with EU WB Directive’s guidelines, Syngenta encourages you to report your concerns through the Syngenta Compliance Helpline or Internal Reporting Channel in your country  first. Syngenta prohibits retaliation of any kind and is committed to the highest standards of ethics and compliance. Any suspected breach can be safely reported and will be treated seriously. If the issue is not resolved, the report to the authorities can still be done.

Please scroll down to Section 11 to check the contact details of relevant Whistleblowing Authorities in your country. Please check the relevant procedures on the authorities’ websites or directly contact them. It is possible that multiple authorities are designated within a single country for receiving EU WB Reports. 

6. What happens after you submit a Report? 

Within 7 days, Syngenta will send the Reporter an acknowledgement of receipt of the report through the same channel it was submitted. You can request us not to send you an acknowledgement of your report**. All reports are carefully investigated in accordance with applicable Syngenta policies and procedures. Within three months from the receipt of the report, Syngenta will notify the Reporter of the outcome of the investigation and of the actions taken (feedback). We maintain open contact channels with the Reporter throughout the investigation, and as part of this, may request further clarification if necessary. 

Please read the Code of Practice for Investigations of Code of Conduct Violations for details. 

7. Whistleblower Protection. 

Syngenta will not tolerate any forms of retaliation against an individual who reports a violation in good faith even if there is insufficient evidence to substantiate the concerns raised.

If a Reporter makes an allegation in good faith, but the allegation is not substantiated by the investigation, no action will be taken against that Reporter as long the Reporter acted sincerely and there is an honest explanation for their concerns. Reports made with bad intentions or to hurt reputations can be considered misuse of the reporting channel and may be subjected to applicable consequences.

If the Reporter was involved in the misconduct reported, they are not exempted from disciplinary action or legal liability. The protection against retaliation does not mean protection against deficient performance and Syngenta´s standards on performance will always remain applicable.

8. Data Privacy. 

Protection of your personal data is taken seriously. Please scroll down to Section 11 to read Data Privacy Notice for your country to check how your personal data is processed and what rights you may have.

9. Anonymous reporting and protecting the identity of the Reporter. 

Reporters may, if they wish, make reports anonymously. However, this usually makes investigations more difficult or lengthy. Also, in some countries, legal entities or authorities are not required to accept and follow up on anonymous reports. Please scroll down to Section 11 to check an option of anonymous reporting in your country.

Syngenta will not disclose the identity of the Reporter to anyone beyond those Syngenta employees or third-party consultants acting for the channel and who are assigned to receive, investigate and provide feedback on reports, except if:

a) you explicitly consent to such disclosure; or 

b) it is required by Union or national law, for example, in the context of investigations by national authorities or judicial proceedings (including safeguarding the rights of defense of the person concerned). 

This obligation to protect your identity will also apply to any other information from which your identity may be directly or indirectly deduced. 

10. Are there any other policies at Syngenta related to Whistleblowing? 

To learn more about Syngenta values and commitment to non-retaliation and fairness, as well about the investigation procedure, please check: 

Code of Conduct

Code of Practice for Investigations of Code of Conduct Violations

The Syngenta Compliance Helpline

11. Country specific information

Please check EU Whistleblower Protection information for your country.

^{* If you submit a report verbally or in a face-to-face meeting, Syngenta will make a record of your report (a transcript of your report or minutes of the meeting) and will provide you with an opportunity to check its accuracy, request a correction if necessary, and sign to approve it.}

^{**except for automated replies}