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"For example, we have a hotline in the US, and we are setting up a helpdesk email for our Gemstones Business. Employees can also report any perceived non-conformances or concerns via their direct managers.

Another line of defence and structure in our corporate governance is our Internal Audit function, led by a VP for Internal Audit and Compliance. The VP reports directly to the Audit Committee on a periodic basis and he has an independent view on risks, compliance and integrity topics. The VP leads a global team who support him in this area."

No mention of any kind of whistleblowing mechanism in the MSA statement.

However in their 2015 Sustainbility Report it mentions:

Pg. 11

"For example, we have a hotline in the US, and we are setting up a helpdesk email for our Gemstones Business. Employees can also report any perceived non-conformances or concerns via their direct managers."