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WHISTLEBLOWING SYSTEM

Last updated : February 6, 2026

1. Purpose of the System

CaliaLabs has established a system for collecting and handling reports in accordance with:

  • • Law No. 2016-1691 of 9 December 2016 on transparency, anti-corruption, and modernisation of economic life (Sapin II Law — French anti-corruption legislation)
  • • European Directive 2019/1937 on the protection of whistleblowers
  • • Law No. 2022-401 of 21 March 2022 aimed at improving the protection of whistleblowers

2. Who Can Report?

This system is open to:

  • • Employees, external collaborators, and service providers of CaliaLabs
  • • Clients, suppliers, and commercial partners
  • • Any person with knowledge of reprehensible facts

3. Reportable Facts

The system covers reports relating to:

Violations of Law

Criminal offences, serious breaches of French or European law, corruption, influence peddling, illegal taking of interests.

Threats to the Public Interest

Serious risks to public health, personal safety, or the environment.

Data Violations

Serious GDPR breaches, undeclared personal data violations, absence of security measures.

Fraud and Corruption

Misappropriation of funds, false invoices, conflicts of interest, favouritism.

4. Reporting Procedure

To submit a report:

Secure Channel

Encrypted email: [email protected]

(Use PGP to guarantee confidentiality. Public key available on request)

Postal Mail

For the attention of the Whistleblowing Officer
CaliaLabs
38 Rue Gabriel Péri
31000 Toulouse, France
(Marked confidential)

5. Guarantees and Protections

  • • Confidentiality: The whistleblower's identity is protected and may not be disclosed without their express consent
  • • Protection against retaliation: No discriminatory measure or sanction may be taken against a good-faith whistleblower
  • • Impartial handling: The report is handled by an independent officer
  • • Acknowledgement of receipt: Within 7 working days
  • • Processing time: Maximum 3 months

6. Report Processing

Processing procedure:

  1. Receipt: The report is recorded confidentially
  2. Preliminary analysis: Admissibility check (within 15 days)
  3. Investigation: In-depth inquiry if the facts are substantiated
  4. Corrective measures: Implementation of appropriate actions
  5. Follow-up: Whistleblower informed of action taken

7. Abusive Reports

Reports made in bad faith, that are defamatory, or manifestly unfounded may expose their author to disciplinary and/or criminal sanctions in accordance with Article 226-10 of the French Penal Code (malicious denunciation).

8. Archiving and Personal Data

Reports are archived securely for 5 years in accordance with the recommendations of the CNIL (French data protection authority). Data is processed in accordance with the GDPR with access restricted solely to the whistleblowing officer.