At HiFi International S.A., we are committed to conducting our business with integrity and transparency and in strict compliance with the laws and regulations applicable in the Grand Duchy of Luxembourg.

Ethics are at the heart of our relationships with our employees, customers, partners, service providers and suppliers. We encourage anyone concerned to report, in good faith, any conduct that may constitute a breach of the law, our Code of Conduct or our ethical principles.

Our reporting system (Law of 16 May 2023)

In accordance with the Luxembourg Law of 16 May 2023 transposing Directive (EU) 2019/1937 on the protection of whistleblowers, HiFi International provides a secure, confidential and independent reporting channel.

Who can submit a report? (Extended scope)

The right to submit a report is available to anyone who has been in contact with our company in a professional context:

• Company employees, including permanent employees, fixed-term employees, part-time employees, students and apprentices;

• External workers, including temporary workers and service providers;

• Former employees and job applicants, including during pre-contractual negotiations;

• Suppliers, subcontractors, shareholders and company directors.

Our Internal Reporting Officers

To ensure complete independence and neutrality, the management of our reporting system has been entrusted to:

• Designated primary reporting officer: Ms Delphine GARBE, Human Resources Director at HiFi International S.A.
• Designated substitute reporting officer: Mr Jean-Philippe ALLAIN, Managing Director at HiFi International S.A., who will intervene in the event of a conflict of interest or if the primary reporting officer is unavailable.
• Confidentiality guarantee: Reports are received and investigated exclusively by the reporting officer to whom they are submitted. The whistleblower’s identity is protected and may not be disclosed without their express written consent.

Submitting a report (Available channels)

We provide several confidential channels through which you may submit information using the method that is most suitable for you:

Written channel (Secure and encrypted)

You may submit a written report, either using your name or completely anonymously, through our independent portal managed by our technical service provider WhistleB (Navex): Access the WhistleB reporting platform

Oral reporting and in-person meetings

Should you prefer to speak directly or request a meeting, you may use our confidential telephone lines:

Direct telephone lines:

• Primary reporting officer (Ms Delphine GARBE): Call +352 691 879 806 or leave a message on her secure voicemail.
• Substitute reporting officer (Mr Jean-Philippe ALLAIN): Call +352 691 879 191, particularly if the report concerns the Human Resources department.

In-person meeting: Upon request, an in-person meeting or secure video conference will be organised by the reporting officer concerned within a maximum of 7 days.

Processing guarantees and statutory deadlines

The Company undertakes to process every report diligently and in accordance with the deadlines imposed by Luxembourg law:

• Acknowledgement of receipt: A written acknowledgement of receipt will be sent to the whistleblower within a maximum of 7 days following receipt of the report.
• Feedback: Detailed written feedback outlining the measures taken to process or investigate the report will be provided to the reporting person within a maximum of 3 months.

Protection against retaliation

Anyone submitting a report in good faith benefits from full protection against any form of retaliation, including dismissal, changes to working hours, transfer to another store or discriminatory measures. Any such measure taken by the employer is automatically null and void pursuant to Article 20 of the Law.

External reporting channels (Public authorities)

Although we encourage you to use our internal reporting channel as a priority in order to enable a swift resolution, you have the legal right to submit your report directly to the competent external authorities in Luxembourg listed in Article 18 of the Law of 16 May 2023, including:

• The Whistleblower Office, Ministry of Justice: 13, rue Érasme, L-1468 Luxembourg | info@osig.lu
• The Inspectorate of Labour and Mines (ITM): 3, rue des Primeurs, L-2361 Strassen | contact@itm.etat.lu

Official documentation available for download

For further information about how our reporting system operates, please consult our complete policy approved by the Staff Delegation: Download our official Internal Whistleblowing Procedure (PDF)