1. purpose and scope
As an international organization with a global emphasis on excellence, the Randstad Group expects all group companies and employees, including directors and officers, to behave at all times in accordance with our core values and Business Principles. This means acting responsibly, with integrity, and in compliance with Randstad policies
and procedures, as well as applicable laws and regulations. We expect our employees to help Randstad maintain its excellent reputation by adhering to the high standards reflected in our core values: to know, to serve, to trust, simultaneous promotion of all interests and striving for perfection.
Randstad promotes a culture of openness and accountability, and encourages all stakeholders to speak up on any (suspected) ethical concerns, dilemmas, or other incidents where conduct falls short of our core values and/or the Business Principles, including serious misconduct and/or unlawful behavior (hereafter “Misconduct”). Speaking up is essential to enable Randstad to protect its people, the company and its values, its other stakeholders and society as whole. However, as we understand that it takes courage to speak up, we want to offer you an easy and safe way to do so.
This misconduct reporting procedure (hereafter the “Misconduct Reporting Procedure” or briefly “Procedure”) explains what your options are to raise your concern and/or to speak up on (suspected) Misconduct in confidence and without fear of retaliation.
This Misconduct Reporting Procedure is applicable globally to all Randstad Group companies, and all stakeholders may use it to speak up on (suspicion of) Misconduct within or relating to the Randstad Group.
2. our procedure - how it works
2.1 introduction
In order to facilitate the reporting of Misconduct (see paragraph 2.2) within or related to the Randstad Group, we have established dedicated channels through which a Stakeholder may voice concerns, either through local reporting mechanisms in place at company level or, for serious misconduct, through a report to the Local Integrity
Officer, the Central Integrity Officer, or through our Integrity Line, the Randstad Group speak-up facility (see paragraph 2.3).
Speaking up on potential Misconduct in accordance with this Procedure ensures you are protected when you make a report (see paragraph 2.5). All concerns about potential Misconduct raised in accordance with our official procedures will be treated confidentially (except to the extent as required to conduct an adequate investigation (including the right of reply of any person accused) and, if necessary, to take appropriate action) and with the assurance that there will be no retaliation against anyone speaking up.
who may speak up
Our Procedure is for any Stakeholder who wants to speak up.
Stakeholder refers to anyone within or outside (with a relation to) the Randstad Group, and may include:
- corporate employees, incl. officers and directors, board members, and trainees
- talent, incl. temporary staffing employees, independent contractors, freelancers, and the self-employed people
- former corporate employees and former talent employed by or through Randstad Group
- candidates and job seekers
- volunteers
- clients and suppliers, and their staff and subcontractors
- shareholders and investors
2.2 misconduct
when to use this procedure
The Integrity Line can be used to speak up on incidents and situations if you reasonably suspect or have evidence of Misconduct within or relating to the Randstad Group ("Misconduct).
Examples of Misconduct (suspected or evidenced) that can be raised under this Misconduct Reporting Procedure include, for example, serious concerns related to:
- Randstad's core values, Business Principles, policies or procedures
- competition and antitrust laws and regulations
- discrimination and racism
- harassment and intimidation
- sexual harassment
- bribery and corruption
- other human rights principles (e.g., modern slavery/forced labor, child labor)
- health and safety failures and environmental issues
- fraud or misappropriation of company assets
- unlawful disclosure of confidential information, including personal data
- conflicts of interest
- criminal offenses
- failure to comply with obligations imposed by law or regulations (including incorrect finance and accounting practices), including any breaches of European Union law (see Annex 2)
when NOT to use this procedure
If you have a question about or an issue with your employment conditions or performance review, payroll or timesheet, your promotion or the workplace environment, this Misconduct Reporting Procedure does not apply. It also does not apply if you have a personal grievance, a conflict with or complaint about your manager or colleague if that does not amount to Misconduct.
You may raise those types of concerns via the appropriate local routes, such as your manager, your consultant or relevant branch manager, complaints or customer service line, or HR department.
If you work at a client of a Randstad Group company, any potential misconduct clearly relating to that client may also be subject to the client’s reporting procedure.
when in doubt
It will not always be easy to assess whether a concern or situation constitutes Misconduct. If in doubt, you may check with the Local Integrity Officer, or just speak up via the Integrity Line (see paragraph 2.4). If you do so, the Local Integrity Officer will review your report and let you know whether it is being followed up as a potential case of Misconduct under this Procedure. If not, you will be referred to the relevant function or reporting line.
2.3 where and how to speak up
Any employee who reasonably suspects or has witnessed potential Misconduct is expected to report it.
For many matters, it can be a good first step to talk to the person involved directly, even though this may not always be easy, or to your manager or other regular (local) reporting channels. Even when we facilitate easy and safe speaking up, this should not immediately replace normal dialogue and feedback, which form the foundation of our core values.
However, if you feel this is not appropriate or you do not feel comfortable doing so, you can report to your Local Integrity Officer or the Central Integrity Officer directly, or make use of the Integrity Line.
your manager, HR representative, legal counsel, risk & audit manager, or other trusted role
As a general guideline, the first person to approach when raising a concern is your direct manager (for employees), your consultant or their manager (for talent), or your regular business contact (other external stakeholders). You may also choose, depending on the nature of the concern, to discuss the matter with your HR representative,
legal counsel, risk & audit, or other trusted party (e.g., ombudsman, confidant) in the organization. They may be able to help, mediate or guide you to the best function to address your concern. Speaking to management is usually the fastest and preferred route, and the best way to ensure a good and open work environment throughout the Randstad Group.
your local integrity officer and the central integrity officer
If your concern relates to potential Misconduct, you may also report directly to your Local Integrity Officer.
The Local Integrity Officer is the impartial person or function that ensures that all cases reported to the Integrity Line as well as those reported to him/her directly, are assessed and then either forwarded to the appropriate team/role for follow-up, or (if the report is assessed as potential Misconduct) investigated and dealt with in a lawful and timely manner, while fully respecting the rights of all individuals involved. Every country/Randstad Group company has its own Local Integrity Officer. The Local Integrity Officer may either be a trusted Randstad employee or an external party, as deemed appropriate by the relevant managing director and the Central Integrity Officer.
Local Integrity Officer contact details:
- email: integriteit@randstadgroep.nl
- address: Diemermere 25, 1112 TC Diemen of Postbus 12600, 1100 AP Amsterdam
If you want to speak with the Local Integrity Officer by phone or in person, please indicate this in your message.
If the suspected Misconduct involves senior management in your company, you can also reach out directly to the Central Integrity Officer at Randstad N.V.
The Central Integrity Officer is the impartial person or function appointed by the Randstad N.V. Executive Board to coordinate integrity issues under this Procedure, and to provide regular reports to the Executive Board and annually to the Audit Committee of the Supervisory Board on cases reported via the Integrity Line or directly to the Local Integrity Officers and Central Integrity Officer.
The Central Integrity Officer ensures that any reports under this Procedure on suspected Misconduct by one or more members of the management team of a Randstad Group company are reviewed centrally.
You may reach out to the Central Integrity Officer by email (complianceofficer@randstad.com), or send a letter to Central Integrity Officer, Randstad N.V., P.O. Box 12600, 1100 AP Amsterdam-Zuidoost, The Netherlands.
the integrity line: online or by phone
If you suspect or have witnessed Misconduct that cannot be reported via the regular reporting channels (e.g., because these are likely to be inappropriate or ineffective, or because you do not feel comfortable reporting your issue through these channels), you can speak up via the Integrity Line.
Reports can be submitted through the Integrity Line in the local language (Dutch or French) or in English, either online or orally (by phone). The Integrity Line consists of a secure webpage and a telephone hotline, accessible 24 hours a day via free local access numbers. Both are operated by an independent external provider. For full contact details and user instructions, see Annex 1.
Although reports may also be submitted anonymously, Randstad encourages you to tell us who you are when you speak up, as this greatly facilitates the investigation of the report.
The Integrity Line details for your country:
- free phone: 0800 0222931
- web access: www.speakupfeedback.eu/web/integrityatrandstaddigital/nl
- access code: 69557
- language options: Dutch, English
The Central Integrity Officer (online only) for the Randstad Group can be reached via:
- web access: www.speakupfeedback.eu/web/integrityatrandstad/nl
- access code: 55984
- language options: English or Dutch (but allow additional time for translation of your message)
Reports made to the Integrity Line are received by the Local Integrity Officer and will also be shared with the Central Integrity Officer at Randstad N.V.
speaking up anonymously
If you want to report anonymously, Randstad strongly advises that you report through the Integrity Line. This allows us to handle your report of potential Misconduct in the most efficient way, helps to minimize unreliable and false reports, best protects the privacy of everyone involved, and enables the Local Integrity Officer and/or Central Integrity Officer to communicate efficiently with you. Randstad does not need to know who you are, but using the Integrity Line makes safe dialogue possible.
When speaking up anonymously, please make sure to provide sufficient details in order to allow your concern to be addressed. Anonymous reports that do not include sufficient details cannot be investigated.
what to include when you speak up
Randstad values any report made in good faith, whether anonymous or not. However, in order to be able to assess the merit of the report and decide on how to follow up, the Local Integrity Officer needs as much detail as possible.
Consider the following aspects when you speak up:
- what happened?
- who is involved - who did what and were there any witnesses?
- when did it happen?
- where did it happen?
- how did it happen - what means or methods were used?
- if you know, why did it happen?
We also encourage you to share any evidence, document, reference, photo, or any other relevant information that may assist us in assessing the report in a more efficient manner. If you do not have such evidence, any reference or recommendation of where to look for such material will be helpful.
You may not be able to address all aspects, but the more information we have, the better we can assess and follow up. When you report via the Integrity Line, the Local Integrity Officer and/Central Integrity Officer may reach out to you (also via the Integrity Line) with further questions.
reporting outside the randstad group
If, after careful consideration, you do not feel comfortable to speak up within the company, it may (subject to specific conditions set by local legislation) be possible to raise your concern outside the company. This procedure is not meant to limit your rights to report the potential Misconduct outside of the Randstad Group nor to limit your protection where external reporting is a possibility under local law. You will still be entitled to protection in the same manner as when reporting internally if, as examples only,
- in the situation where you have first reported internally, no response was provided to your report within the timeframe set in paragraph 2.4;
- in spite of our clear commitment in this procedure, you seriously fear there is a risk of retaliation;
- the breach you suspect or have evidenced constitutes an imminent or manifest danger to the public interest (an emergency situation or a risk of irreversible damage).
However, reporting externally to a local authority or publicly is an impactful step. To understand all conditions involved, and what can or cannot be reported externally, please see the website of the competent authorities in your country of residence. In addition to reporting via the Integrity Line, you can also report to:
Het Huis voor Klokkenluiders
contact details:
- t: 088 – 133 10 00
- email: contact@huisvoorklokkenluiders.nl
For information about reporting or a request for investigation.
For advice when reporting:
- On working days between 10.00 o’clock and 12.00 o’clock and between 13.00 o’clock and 16.00 o’clock.
- t: 088 – 1331 030
- email: advies@huisvoorklokkenluiders.nl
Depending on the subject matter other authorities may have jurisdiction:
- autoriteit Consument & Markt (ACM)
- autoriteit Financiële Markten (AFM)
- autoriteit Persoonsgegevens (AP)
Whenever you are considering this, we strongly recommend that you seek advice and not do this alone. Above all, we strongly encourage that you speak up within the company first, so you can hand the burden over to us, and we will be able to look into the matter immediately.
If you decide to report potential Misconduct externally while an investigation by a Randstad Group company is ongoing, the company may decide to no longer involve you in that investigation, to stop the investigation, and/or take any other steps it considers necessary.
2.4 handling of reports made via the integrity line or directly to the local integrity officer
Reports received through the Integrity Line are shared with the Local Integrity Officer. As standard, a copy of the report is also sent to the Central Integrity Officer at Randstad N.V.
Both the Local Integrity Officer and the Central Integrity Officer are impartial functions. The Integrity Line, the Local Integrity Officer, and the Central Integrity Officer offer a secure way to speak up. This way of speaking up ensures you are using reporting channels that protect your confidentiality as well as that of third parties. Access to non-authorized persons is restricted.
initial assessment and response
The Local Integrity Officer will confirm to you the receipt of your report, received directly or through the Integrity Line, within seven days of receipt. The Local Integrity Officer will also inform you whether the matter reported is assessed as a potential Misconduct, or whether it is a matter that should be handled through the normal (local) reporting procedures (e.g., HR representative, client contact, payroll, complaints, or customer service & support line). If further information is required to make this assessment, this will be addressed in the response message.
If the matter should be handled through the normal (local) reporting procedures, the Local Integrity Officer will provide the relevant details in the response message, or contact the relevant local function to handle the report, depending on the nature of the message and the contact details that you provided.
the investigation and feedback
The Local Integrity Officer ensures that all reported cases of potential Misconduct are investigated and dealt with in a lawful and timely manner, while respecting the rights of all individuals involved, in accordance with Randstad's investigation procedure.
In certain instances such cases may be referred to and handled by a local management representative and/or other relevant functions of the company, depending on the nature of the report. In these cases, the same practices with regard to, for example, confidentiality, non-retaliation and timeframes still apply.
After due assessment, the Local Integrity Officer may decide not to investigate a report if, for example:
- there is insufficient information for a fair investigation and it is not possible to obtain further information;
- there is a clear indication that the report was not based on merit, but was made in bad faith and with the mere intention to harm individuals or the company rather than to address Misconduct.
During the investigation, the Local Integrity Officer or other relevant function involved in the investigation may also reach out to you (via the Integrity Line or, when possible, directly) for further clarification.
At the latest 3 (three) months from the acknowledgement of receipt, the Local Integrity Officer will provide feedback. If the investigation is not yet concluded at that time, further feedback will be provided again at a later moment. Please note that it is not always possible to share the details of the progress or outcome of the investigation for reasons of confidentiality, privacy and the legal rights of the parties involved. All parties are entitled to confidentiality, including the accused. Therefore, if you participate in or learn about an investigation, you must also keep the matter confidential.
the central integrity officer
If the potential Misconduct involves one or more members of the local management team of a Randstad Group company, the Local Integrity Officer will redirect the report to the Central Integrity Officer. The Central Integrity Officer may inform local management and will inform the responsible member of the Randstad N.V. Executive Board and/or the Audit Committee of the Supervisory Board, subject to confidentiality and there being no potential conflict of interest.
Reports that relate to one or more members of the Randstad N.V. Executive Board or Supervisory Board will be handled by the Randstad N.V. Local Integrity Officer, who is a member of the Supervisory Board.
conclusions and actions taken
After the investigation is concluded, prompt and appropriate corrective action will be taken when and as warranted in the judgment of the relevant management level, taking into account the relevant company functions (e.g., HR, Legal). Corrective action in the event of proven Misconduct may vary from a written warning, coaching, and/or apologies to those affected by the Misconduct through to the suspension or termination of the contract of or relationship with the person/those responsible for the Misconduct, reporting to the appropriate authorities, and/or any other action relevant and proportional to the specific Misconduct.
2.5 protecting your rights when you speak up via the integrity officer and/or integrity line
Protecting your right to speak up on potential Misconduct is essential. One of the main purposes of this Procedure is exactly that. This protection applies when you have reasonable grounds to believe that the information you report is true at the time of reporting, and this information constitutes Misconduct.
Below, some key principles are highlighted.
confidentiality
All concerns raised via the Integrity Line or with the Local Integrity Officer directly are treated as confidential to the maximum extent, including your identity, consistent with the need to conduct an investigation (and, if necessary, take appropriate action). This also applies to anyone assisting you when speaking up in a work-related context. Exceptions to confidentiality are possible when Randstad is under a legal or regulatory obligation to disclose the information, or if the report is made in bad faith.
Information will only be shared with a limited number of authorized people directly involved in the investigation on a strict need-to-know basis. This may include external advisors involved in an investigation. Your identity and other information from which your identity may be deduced will not be disclosed to anyone beyond these people without your explicit consent. Depending on the purpose of sharing, the Local Integrity Officer will (further) anonymize the information prior to sharing it.
In principle, we are obliged to inform any person under investigation that he or she is the subject of an allegation of potential Misconduct. This notification may be delayed if there is a substantial risk that this jeopardizes the investigation or the gathering of evidence. Also in this case your identity will not be disclosed.
When you speak up in accordance with this procedure, Randstad is committed to treating your report seriously and with care. Randstad expects that you treat it in the same manner, also respecting confidentiality to the extent possible, in accordance with your contractual and confidentiality obligations. This does not restrict you from reporting externally or publicly where this is possible under local law, in accordance with the specific requirements for such reporting, or from seeking (legal) advice in relation to your reporting (see paragraph 2.3, reporting outside the Randstad Group).
privacy/data protection
Any personal data obtained as part of any report and investigation under this Procedure (including of the person speaking up, any person under investigation, and any witnesses) will only be used for the purposes described in this Procedure and in accordance with relevant data protection laws and Randstad's data protection policy. Personal data that is clearly not relevant for handling of a specific report shall be deleted without undue delay.
Personal data on the Integrity Line will be deleted by the Local Integrity Officer three months after a case is closed. Personal data collected as part of an investigation may be retained for a longer period if this is required due to the nature of the allegations and/or investigation up to the maximum statutory limitation period for the relevant country, but no longer than is necessary and proportionate.
Personal data will only be shared with those who need to know and will be subject to an obligation of confidentiality to the extent possible and as consistent with the need to conduct an investigation and, if necessary, take appropriate action. Exceptions are possible if Randstad is under a legal or regulatory obligation to disclose the information or if the report is made in bad faith.
non-retaliation
We encourage speaking up, and any person who speaks up will be protected from any form of threat or retaliation, provided that the reporting person has reasonable grounds to believe that the information on the potential Misconduct reported is true at the time of the report. You will not be blamed or held liable when you report in good faith and in accordance with this Procedure.
Randstad will not retaliate against anyone reporting potential Misconduct. For example, Randstad will not discharge, demote, suspend, threaten, harass, or in any manner discriminate against anyone reporting potential Misconduct. This also applies to the person who assists the person speaking up in a work-related context.
The right of non-retaliation is guaranteed under the Business Principles, and violation of this right will not be tolerated. Any form of threat or retaliation aimed at speaking up may lead to disciplinary measures.
If you notice or experience any threat or retaliation, you can report this via the Integrity Line or directly to the Central Integrity officer. When you speak up in accordance with this procedure on Misconduct in which you have participated yourself, Randstad will consider taking this into account as a mitigating factor when assessing the consequences of such Misconduct.
exception: reporting in bad faith
Reports are considered to have been made in bad faith if the reporting person knows, at the moment of reporting, that the allegation made is not true. This could be the case, for instance, when this Procedure is abused (a) because of personal grievances, (b) for personal benefit, or (c) to intentionally harm the Randstad Group or (any of) its employees, including officers and directors. The Randstad Group sees reporting in bad faith as a very serious violation of our Business Principles.
If appropriate, the Randstad Group may take further action (including disciplinary action) against anyone who knowingly makes a report in bad faith.
2.6 protecting the subject of an investigation
A person subject to an investigation into a potential Misconduct is also entitled to protection. The presumption of innocence is a leading principle. The Local Integrity Officer is responsible for monitoring and managing this Procedure, also towards anyone who is accused of – or otherwise involved in – any potential Misconduct.
The person under investigation of a potential Misconduct will normally be notified of this fact within a reasonable timeframe, depending on the facts and circumstances and whether there is a perceived risk of destruction of evidence, retaliation and/or obstruction of the investigation.
All questions or issues raised are treated confidentially. Information will only be shared with a limited number of people on a strict need-to-know basis.
The person under investigation has the right to respond to the allegations and can appeal against any adverse findings or decisions.
3. accountability and disciplinary action
The Randstad N.V. Executive Board has overall responsibility for the Misconduct Reporting Procedure and its application. Management of each Randstad Group company is obliged to ensure that this Misconduct Reporting Procedure is implemented within its organization, and the Local Integrity Officer can function in accordance with this Procedure.
Randstad expects management at all levels within the Randstad Group to handle all reports concerning any potential Misconduct seriously, confidentially, and in an expeditious manner, and to ensure that the reporting person is not confronted with threats or retaliation. Management is obliged to fully cooperate with any investigation into potential Misconduct.
Failure to comply with this Procedure, including threats or retaliation against anyone speaking up in accordance with this Procedure, and failure to take reasonable steps or reasonable care to protect the identity of the person speaking up may be subject to disciplinary action.
The Randstad N.V. Executive Board, after consultation with the Supervisory Board, may amend this procedure at any time in a manner consistent with the requirements of applicable laws and regulations, and will involve the Randstad European Works Council. Where relevant the local Works Councils will be involved for local implementation.
annex 1 - user instructions & contact details
integrity line user instructions
When you prepare to speak up via the Integrity Line, consider the following aspects for reporting:
- what happened?
- who is involved - who did what and were there any witnesses?
- when did it happen?
- where did it happen?
- how did it happen - what means or methods were used?
- if you know, why did it happen?
If possible, you may share, along with the online report, any evidence, document, reference, photo, or any relevant information, which may assist us in assessing the report in a more efficient way. If you do not have such evidence, any reference or recommendation of where to look for such material will be helpful.
free phone line - reporting orally
The Integrity Line details for your country:
- free phone: 0800 0222931
- web access: www.speakupfeedback.eu/web/integrityatrandstaddigital/nl
- access code: 69557
- language options: Dutch, English
The Central Integrity Officer (online only) for the Randstad Group can be reached via:
- web access: www.speakupfeedback.eu/web/integrityatrandstad/nl
- access code: 55984
- language options: English or Dutch (but allow additional time for translation of your message)
The person reporting dials the applicable free phone number; the telephone call is received by a voice-response system. After making the report, the reporting person receives a unique case number. The report can be made in the local language (Dutch or French) or in English. The external provider then sends a word-for-word transcript of the voice recording to the Local Integrity Officer. Please consider the following guidelines:
- please speak clearly
- if you want to be contacted directly, make sure you leave your contact details; your phone number is NOT registered when you report by phone
- register your unique case number for communication purposes
For protection of the reporting person’s anonymity, the voice recording remains with the external provider and is destroyed as soon as the Local Integrity Officer has confirmed receipt of the transcript.
Via the unique case number, the Local Integrity Officer will leave a reply message for the reporting person to confirm receipt of the report and, if necessary, to ask verification questions or summarize a conclusion. The person reporting has the right to receive a written receipt of the report and to review and correct the report. After the initial report, the Local Integrity Officer will send a confirmation of receipt within a maximum of seven days from receipt of the message. Please check for a response message! Your phone number is not registered when you report.
Using the unique case number, the person making the report can call the free phone line again to hear the reply from the Local Integrity Officer. The person reporting can choose whether to answer questions immediately or at a later stage.
online reporting form
- The person making the report goes to the relevant web page, leaves a message by entering a text (in the local language (Dutch or French) or in English), and receives a unique case number. The external provider translates the message (if not in English) and sends the translation plus a copy of the web message to the Local Integrity Officer.
- Via the unique case number, the Local Integrity Officer can leave a reply message for the reporting person to confirm receipt of the report and, if necessary, to ask verification questions or summarize a conclusion. After the initial report, the Local Integrity Officer will send a confirmation of receipt within a maximum of seven days from receipt of the message.
- The person making the report can use the case number to log in again, and will then be able to see the reply from the Local Integrity Officer. The person reporting can choose whether to answer questions immediately or at a later stage.
annex 2 - breaches of european union law
The following breaches shall be seen as a breach of European Union Law:
a) Breaches of European Union law in the following areas:
- public procurement;
- financial services, products and markets, and prevention of money laundering and terrorist financing;
- product safety and compliance;
- transport safety;
- protection of the environment;
- radiation protection and nuclear safety;
- food and feed safety, animal health and welfare;
- public health;
- consumer protection;
- protection of privacy and personal data, and security of network and information systems.
b) Breaches affecting the financial interests of the Union as referred to in Article 325 TFEU and as further specified in relevant Union measures;
c) Breaches relating to the internal market, as referred to in Article 26(2) TFEU, 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.