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Fifty5Blue is committed to:

We want to behave with integrity and treat others with respect. During your work, you may be confronted with ethical concerns or dilemmas. We encourage you to raise any concerns you have about the way that Fifty5Blue operates and conducts its business, or about any suspected danger or wrongdoing. This keeps us all accountable and helps us continually improve our business and culture.

We understand that it takes courage to speak up, so therefore we are committed to providing you with an easy and safe way to raise your concerns. Speaking up is an essential  part that enables us  to protect our people, our company values, our stakeholders and society as a whole. No one should be alone when dealing with an ethical dilemma. In this document (our Right to Speak Policy) we clearly explain what your options are and how you can raise your concerns.

The legal systems of some countries may have different requirements and give individuals who report issues different protections than Fifty5Blue policy. In the event of a divergence between Fifty5Blue’s Right to Speak Policy and local law, local law will prevail. You can find a list of countries and the different protections offered here.

What’s included in this policy?

This Policy summarises:

Before we get into the details of the Policy, it’s useful to clarify what we mean by certain terms. In this Policy references to the following terms shall have the meanings set out below:

“Fifty5Blue” means each company in the Fifty5Blue group of companies.

“Report” means an oral or written disclosure of information or a reasonable suspicion, about an actual or potential breach, which has occurred or is very likely to occur. It also covers an attempt to conceal such breach.

“RTS” means Right to Speak.

Who does this policy apply to?

This Policy applies to:

For clarity, this Policy does not form part of any contract of employment or engagement and Fifty5Blue may withdraw or amend it at any time.

What kind of concerns can be raised via Right to Speak?

Right to Speak can be used to report any concerns you have about the way that Fifty5Blue operates and conducts its business, or about any suspected danger or wrongdoing. This includes any actual or suspected breach of the Fifty5Blue Policy Book, the law or our regulatory requirements. For example, this could include reports about any of the following, but please note that this is not an exhaustive list:

How do I report a concern?

You can raise a concern, provide feedback or ask your questions in a variety of ways. For many matters, it can be a good first step to talk to the person involved directly. Thus, our Right to Speak Policy and process should not entirely replace the direct dialogue that forms the foundation of our transparent company culture. However, we recognise that this is not always easy to do.

If this is not possible, or if you do not feel comfortable doing so, please turn to our Right to Speak channels as described below:

  1. Speak to your manager or your manager’s manager
  2. Speak to your local HR representative or email Compliance at [email protected]
  3. Raise your concern via SpeakUp

In the annex ‘contact & useful links’, you will find all relevant practical details.

What information should be provided when raising a concern?

When making the report you should expect to provide the following information:

Individuals making a report do not need proof of their suspicions in order to raise a concern. They must, however, have reasonable grounds to believe, given the circumstances and the information available to them at the time of reporting, that the matters they are reporting are true.

Personal data will be collected, processed and used only for handling the reported concern. Details of how your personal data is handled are set out in the RTS Privacy Notice.

Do I have to give my name?

You can make a report anonymously and we make every effort to investigate anonymous reports as far as possible.

For anonymous reports made outside SpeakUp, we can only rely on the information initially disclosed. A lack of sufficient information in the initial report may mean we are not able to investigate properly to adequately address the concern and improve our working practices and culture. For anonymous reports made via SpeakUp, we can raise comments, follow up and provide updates via SpeakUp which you should check weekly. This makes safe dialogue in an anonymous way possible.

Where appropriate, and subject to local law restrictions, we encourage reporters to provide their contact details. This is so the investigator can liaise with you to get relevant information to conduct a purposeful and meaningful investigation, recommend appropriate remedial action and let you know the outcome, if appropriate. Every concern raised, whether via SpeakUp or otherwise, will be treated confidentially, and will be promptly and thoroughly reviewed and, where appropriate, investigated.

I raised a concern, now what?

If you submit a concern, you will receive an acknowledgement of receipt within five working days. Your report will be evaluated and the appropriate course of action will be determined. Sometimes you will be asked follow-up questions. So far as possible, you will receive feedback within a reasonable timeframe and no later than three months after the acknowledgement of receipt of the report. Feedback may include:

Please note that we may not be able to give you details of the outcome of the investigation for reasons of confidentiality, privacy and the legal rights of the involved parties.

Please also note that not all issues raised will automatically lead to a formal investigation. Sometimes following another course of action is better for all parties involved (e.g. mediation). Furthermore, sometimes there is insufficient information for an adequate investigation to take place and there is no possibility of obtaining further information.

Confidentiality and protection for individuals raising a report  

We are committed to ensuring that employees feel able to raise concerns openly under Right to Speak, without fear of reprisal, retaliation or victimisation and with the support of Fifty5Blue.

All investigations will be carried out confidentially to the fullest extent possible and with the appropriate level of sensitivity. Only a limited number of individuals will be aware of and/or involved in the investigation, unless Fifty5Blue is otherwise required or compelled by law to disclose information. Those knowing the identity of the individual raising the report will therefore be kept to a minimum.

Fifty5Blue does not tolerate any form of retaliation or victimisation in relation to a report being raised or involvement in a Right to Speak investigation. This is not only reprehensible and contrary to our culture, but it could give rise to legal action being taken against Fifty5Blue.

Retaliation includes not only actions taken by Fifty5Blue or any of our colleagues, but also actions taken by our clients or the recipients of our services and anyone working for them.

Examples of retaliatory action for making a report which will not be tolerated by Fifty5Blue include:

Please note that this is not an exhaustive list.

Any retaliatory action will be taken extremely seriously and may result in a separate investigation and appropriate disciplinary sanctions against the perpetrator being taken. This is whether or not the initial report is found to be true.

If you believe that you have suffered or are the subject of retaliatory action please inform the investigator immediately or raise a report via this RTS process. This will then be discussed with the Fifty5Blue Legal Team.

Contact details and useful links

Raise your concern online here – https://kantarmedia.speakup.report/en-GB/raiseyourconcern/home

You can leave a report via phone. Please refer to this list for the correct telephone number for your country –

RTS Phone numbers by Country

Please quote our organisation code when raising a concern via phone – 127070

Alternatively you can scan this QR code and raise your concern on your device –