1. Scope
At Frontify (which means Frontify AG and its subsidiaries), we are steadfast in our commitment to transparency, integrity, and accountability. This grievance resolution and whistleblowing policy (“Policy”) provides a secure and confidential path for raising concerns, filing complaints, and reporting serious misconduct. This Policy is available to our employees, the employees of our customers and subcontractors, our contractors and freelancers, and any other relevant stakeholders to report their concerns about such issues involving Frontify or affecting the public interest.
Matters that can be raised under this policy comprise both general workplace concerns and serious misconduct, including but not limited to the following categories:
- Financial misconduct, such as fraud, corruption, improper gifts or facilitation payments, and labor conditions
- Harassment or discrimination
- Violations of company policies or legal infractions
- Retaliation related to a whistleblowing case
- General workplace concerns and grievances, such as interpersonal conflicts, work environment issues, and operational challenges
2. Compliance with legal and regulatory requirements
This Policy aligns with the EU Whistleblower Protection Directive (2019/1937), Swiss law, UK, US, and NY State Law, and other applicable whistleblower protection regulations. Frontify shall take all reasonable measures to ensure that its whistleblowing processes comply with all applicable data protection laws — including GDPR, the UK GDPR, the FADP, and the CCPA — to safeguard the privacy of all involved parties.
3. Reporting mechanisms
3.1. Anonymous reporting
Frontify is dedicated to preserving the anonymity of reporters and/or facilitators. Cases can be submitted through the following link to our whistleblowing platform: https://frontify.personiowhistleblowing.com. Frontify’s employees can access this link via Personio, while anybody else can access it via our website by checking the “Legal and Privacy” section under Corporate Social Responsibility. Thanks to best-in-class security standards, Personio safeguards the reporter’s anonymity. We ensure anonymity — no personal data related to the reporter is required or requested to be disclosed inunethical or illegal activities. If a Frontify employee accesses the link through Personio, it redirects them to an external website, ensuring that no personal data is saved.
To report a possible violation, reporters must fill out a form and provide Frontify and its team of internal case managers with all relevant information necessary to investigate the cases and create a final report. Only case managers or people on a need-to-know basis will have access to the reported cases. Reporters can monitor the progress of their cases, provide additional information related to the case, or communicate with the case manager through a unique case code they must save when submitting a case. This code ensures that the reporter doesn’t need to provide any personal information but is still able to communicate with the case managers and have access to the final outcome of their case.
We strongly encourage individuals to raise workplace concerns or report suspected wrongdoing in good faith, assuring them they can do so without fear of retaliation. Whether the matter is a general grievance or serious misconduct, all cases will be treated with the utmost confidentiality and investigated impartially.
Frontify is committed to providing comprehensive support to reporters and/or facilitators. Reporters seeking such assistance can request details through the whistleblowing platform or directly contact the Legal Team or People Team to ensure they receive the necessary resources and support throughout the reporting process.
3.2. Other reporting mechanisms
In cases where reporters prefer alternative methods that don't guarantee anonymity, cases can also be reported via the following channels:
- Confidential email reporting via whistleblowing@frontify.com
- In-person reporting to your manager or People Partner
Frontify is committed to ensuring anonymity to the greatest extent possible when using these methods. Under no circumstances will Frontify, the case manager, or your manager/People Partner intentionally disclose any information related to the case.
4. Protection against retaliation
Frontify strictly prohibits retaliation against reporters or facilitators who report concerns in good faith, including but not limited to termination, demotion, suspension, threats, harassment, and discrimination. Any employee found to have engaged in retaliatory actions against a reporter will face harsh disciplinary measures, up to and including immediate termination of employment or of the respective contractual relationship. This commitment underscores our dedication to fostering an environment where employees, contractors, and stakeholders feel safe and supported in reporting unethical or illegal activities.
Individuals can report any concerns about retaliatory actions they have experienced or witnessed directly through the whistleblowing channel. All claims are addressed promptly and impartially by the VP People and the Legal Lead. Frontify is committed to thoroughly investigating all retaliation claims and taking appropriate remedial steps to protect the rights of the complainant.
5. Internal reporting process
5.1. Case management
Upon receipt of a case, two designated case managers, one from the Legal Team and one from the People Team, will review it and collaborate to address any concerns, investigate, and propose a solution. For general workplace grievances, the People Team may handle the matter independently, while matters involving potential misconduct will always involve both teams. The designated case managers might involve an additional case manager from the Security Team if they believe that this is necessary to guarantee a thorough investigation. The case managers have been trained in grievance resolution and whistleblowing procedures and are bound by strict confidentiality obligations. This dual-review system ensures compliance with regulatory requirements and promotes impartial handling of all cases. Case management might be escalated to senior management, the Legal Lead, and the VP People, or an external party under specific circumstances listed below.
5.2. Acknowledgment and updates
We’re committed to timely and continuous communication regarding the status of cases. We’ll acknowledge receipt of submissions within seven calendar days. A substantial update on the investigation's progress will be provided within one month, or at most, three months after acknowledgment. Frontify aims to complete the investigation and provide a resolution as soon as possible, with the goal of closing the case within six months of receiving it. If additional time is needed due to case complexity, the reporter will be informed with clear reasoning for the delay.
While direct updates will not be issued to the reporter, the reporter can track the progress of their case using the unique case code provided at the time of submission.
5.3. Case processing
The case managers will conduct an initial assessment to determine the necessity of a formal investigation. This process may involve gathering evidence and conducting confidential interviews with involved parties. If misconduct is substantiated, appropriate remedial actions will be implemented, including disciplinary measures, process improvements, or legal action. A case will be considered closed once all necessary actions have been executed and no further investigation is warranted. The case managers will conclude the investigation with a final report summarizing the case, its developments, the investigation, the outcome, and the possible next steps and their enforcement. Reporters will be informed of the outcome; this can be either a redacted final report or a written explanation, including the grounds on which a reported grievance or activity was not investigated further. Reporters will have access to this information with their unique case codes. Upon the case managers’ discretion, the full final report can be shared with the reporter.
5.4. Retention policies and personal data handling
Frontify is committed to maintaining comprehensive records of all cases and related documentation. Final reports shall be stored no longer than necessary and proportionate. At the conclusion of the investigation, records will be reviewed to determine if further retention is warranted based on ongoing legal or business needs. If no such needs are identified, the records will be securely disposed of, ensuring that all data protection and confidentiality obligations are met. This retention period ensures compliance with applicable legal and regulatory requirements and facilitates ongoing review and analysis of whistleblowing activities.
Only personal data that’s relevant and necessary for handling a whistleblowing case will be collected. Any personal data that’s not relevant will not be collected or, if inadvertently collected, will be deleted without undue delay. All personal data processed in the context of whistleblowing will be handled in accordance with the General Data Protection Regulation (GDPR) and any other applicable data protection laws.
All records will be securely stored to protect their confidentiality and integrity. Access to these records will be restricted to authorized personnel only, and measures will be in place to prevent unauthorized access, alteration, or destruction.
5.5. Escalation
Any escalation authority under this policy shall rest with the VP People and the Legal Lead, who can assess and determine appropriate actions in response to escalated cases. If the VP People and the Legal Lead are unable to resolve the matter, it shall be further escalated to the Board of Directors for final determination. This ensures impartiality, compliance, and adherence to the principles outlined in this policy.
Reporters and/or facilitators have the right to seek an independent review of their case upon request in accordance with applicable legal and procedural standards. The requesting party must submit a reasoned and substantiated written justification demonstrating why an external review is required. Any such request shall trigger an escalation process whereby the case managers, in consultation with the VP People and the Legal Lead, assess the necessity of an independent external review.
Alternatively, reporters and/or facilitators can share their concerns directly with external regulators or relevant authorities, particularly when internal reporting mechanisms don’t satisfactorily resolve the issue or where the reporter perceives a risk of retaliation. Frontify acknowledges the importance of ensuring reporters can seek external resolution without fear of reprisal. This right aligns with applicable legal frameworks and underscores our commitment to transparency and accountability. Any such external cases should be made in good faith and in compliance with relevant legal standards.
5.6. Bias prevention
To prevent biases, measures such as anonymous case assignments and regular audits of the grievance resolution and whistleblowing process will be established and employed. Additionally, employees involved in the review process shall disclose any potential conflicts of interest before accepting a case.
When a case implicates senior management or members of the Legal Team or People Team, it will automatically escalate to an independent review panel or external legal counsel to ensure impartiality. The Board of Directors will oversee the case.
6. Training and communication
To ensure the effectiveness of this Policy, Frontify will provide regular training to all employees and other relevant stakeholders on the importance of grievance resolution and whistleblowing, procedures for reporting concerns, and the prohibition of retaliation. Training completion will be documented and monitored. This Policy will be communicated regularly and included in employee onboarding materials to reinforce our commitment to ethical conduct.
7. Conclusion
Frontify remains committed to upholding ethical business practices and ensuring a secure, confidential, and impartial grievance resolution and whistleblowing process. This Policy will be reviewed and updated regularly or as required by changes in applicable laws or business circumstances. This Policy reinforces our dedication to compliance, fairness, and accountability. Any questions regarding this Policy should be directed to the Legal Team or People Team, or whistleblowing@frontify.com.