This Integrity Helpline is a confidential and, if you choose so, anonymous online reporting system provided by Adient plc and its subsidiaries worldwide to allow you to ask questions and to report concerns relating to potential violations of Adient’s Ethics Policy and/or applicable laws.
I consent with the collection of my Personal Information as described in the Integrity Helpline Privacy Notice available [https://www.navexglobal.com/en-us/privacy-statement]
I. Introduction
General. This privacy notice (hereinafter: “Notice”) sets forth data protection measures taken by Adient plc and its subsidiaries worldwide (hereinafter: “Company”). The Company has retained NAVEX to provide compliance services for the reporting of potential violations of Adient’s Ethics Policy and/or applicable laws. The Company requires NAVEX to take adequate measures to protect and secure all Personal Information that is reported via the Adient Integrity Helpline. Personal Information means all information that can be directly or indirectly linked to an identifiable individual.
The use of the Integrity Helpline is voluntary.
II. Scope and Purposes of the Integrity Helpline
Type of Issues. The issues and concerns that can be reported through the Integrity Helpline generally include the following types of matters: (i) accounting, auditing and financial reporting, (ii) business integrity (general compliance); (iii) employment and diversity; (iv) employment integrity; (v) enterprise security; (vi) health, safety and environmental; (vii) international trade; (viii) product safety; and (ix) inquiries. Personal Information collected through the Integrity Helpline will be processed for the purposes of compliance reporting, investigating, follow-up and remedying reported matters.
III. Use of the Integrity Helpline
Good Faith Use. Adient expects reporting individuals to act in good faith when submitting a report through the Integrity Helpline.
Information Collection and Minimization. Only factual data relevant to the allegation should be provided. The following information may be processed: (i) identity, function and contact details of the reporting individual, implicated person(s), and of persons intervening in the processing of the reports (e.g., call center personnel/technical staff at NAVEX); (ii) facts of the incidents that are reported; (iii) evidence collected and facts in the context of the verification of the reported facts; (iv) summary of the investigation and the verification of facts; and (v) outcome of the investigation.
IV. Information Security and Confidentiality
General. Whether a report is made via the toll-free number or via the secure web-based reporting site, https://adient.ethicspoint.com, the Company has taken measures to maintain Personal Information in a secure web-based application and to protect such information from unauthorized access or disclosure, accidental or unlawful destruction or accidental loss or alteration. All persons involved in the management of the Integrity Helpline must ensure that information received is handled confidentially and subject to information security measures.
Limited Access. The information, including Personal Information, in the Integrity Helpline database may only be reviewed and used by those individuals who need to know the information to fulfill their professional duties. These individuals may include, but are not limited to, appropriate employees from Human Resources, Internal Audit, Legal, Security, Finance, or other Company departments or functions or technical staff at NAVEX [?]. Furthermore, Personal Information contained in reports may be made accessible to (i) the reporting individuals (taking into account the obligation to keep the identity of the reporting individual confidential); (ii) the relevant Company entity in order to take disciplinary action or to prepare for or respond to court proceedings; and (iii) the police, the public prosecutor or other public authorities. In such cases, only the relevant information necessary for the required action will be disclosed.
Confidentiality. The Company takes reasonable and appropriate measures to maintain the confidentiality to the extent practicable given the nature of the investigation. The identity of the reporting individual will not be disclosed to the implicated person(s) or his/her superior(s) (unless the latter is required in the course of the investigation to prevent any retaliation against the reporting individual or another legitimate business interest exists for such disclosure).
V. Handling of Reports and Investigation
Reports submitted to the Integrity Helpline will be forwarded to the appropriate investigator. The investigator may consist of members from Legal, Human Resources, Internal Audit, Security, Finance, and other departments or functions, as appropriate.
VI. Rights of Reporting Individuals and Implicated Persons
Data Protection Rights. Reporting individuals can exercise their rights of access and rectification under applicable data protection laws by contacting the Compliance team. The rights of rectification and erasure only concern Personal Information that is objectively inaccurate, incomplete, ambiguous or outdated. The Company may restrict data protection rights in order to preserve the protection of the rights and freedoms of other data subjects involved in the alleged wrongdoing as well as to safeguard the integrity of the investigations.
VII. Evaluation of the Helpline
The Integrity Helpline may be evaluated from time to time. Such evaluation shall be conducted without access to personal identifiers and evaluation reports shall not contain Personal Information.
VIII. Storage of Information
Reports and information related to investigations, including Personal Information, will be stored for seven (7) years, unless the Company has a legitimate business interest or legal obligation for retaining such information longer.
IX. Contact Information
Please contact Adient’s Privacy Office, https://www.adient.com/privacy, if you have questions or concerns concerning the handling of your Personal Information through the Integrity Helpline.
Additional Provisions for EU and Asia-Based Residents
Supplementary Nature of Reporting. The Integrity Helpline is complementary to other means of communication to report compliance issues or misconduct as outlined in Adient’s Ethics Policy.
Data Controller Contact Details. Adient plc (registered in Ireland, 25-28, North Wall Quay, IFSC, Dublin 1, Ireland) is the data controller of the Integrity Helpline. Affiliated Adient entities may act as separate data controllers to the extent they handle Personal Information reported via the Integrity Helpline for purposes of investigation and/or follow-up on reported matters. For more information about Adient Affiliates that may be data controller, please consult Adient’s portal at Adient.com.
Legal Basis of Processing. Personal Information included in reports are processed based on the consent provided by the reporting individual. The Company relies on its legitimate interests to process Personal Information of the implicated individuals. Specifically, the legitimate interests are (i) Adient’s compliance with applicable regulations as highlighted in Adient’s Ethics Policy; (ii) protection of employees, customers, the Company and third parties; (iii) Adient’s business and financial interests; and (iv) ensuring business continuity.
Data Protection Rights. Implicated individuals in the EU can also invoke the aforementioned Data Protection Rights. These rights can be restricted in order to preserve the protection of the rights and freedoms of other data subjects involved in the scheme as well as to safeguard the integrity of the investigations. In addition, Reporters and implicated individuals in the EU have a right to request the restriction of processing and a right to object to the processing of Personal Information in the context of the Helpline. These rights are not absolute and the right to object may, in specific cases, be overridden by the Company’s specific compelling legitimate grounds, or by the fact that the information is required for the establishment, exercise or defense of legal claims. In all cases, individuals have a right to file a complaint with the Supervisory Authority in their country of residence.
Data Retention. Adient maintains data within NAVEX for seven years.
Onward Data Transfers. Personal Information included in reports will be transferred to NAVEX in the United States. For personal information collected in the EU, the onward transfer to NAVEX is based on Standard Contractual Clauses. To the extent that Adient’s affiliates need to access Personal Information, such data transfers rely on Adient’s Binding Corporate Rules (hereinafter: “BCRs”). You can find a copy of Adient’s BCRs here (https://www.adient.com/privacy).
Contact Information Data Protection Officer. If you have questions about the handling of Personal Information in the context of the Integrity Helpline, or more generally about Adient’s data privacy program, please contact Adient’s Privacy Office (privacy@adient.com).