Version 1.1 April Philips Travel Risk Policy

Transcription

1 Version 1.1 April 2016

2 Contents Version History... 3 List of acronyms Introduction Purpose Scope Decision-Making Authority (DMA) Travel to High and Extreme travel risk countries Policy Ownership and Review Travel Risk Services Country Briefings Travel Tracking Travel of Dependents Roles and Responsibilities Travelers and Expats Country Managers (CMs) / Market Leaders (MLs) Risk Management Markets & Business Development support (RMM&BDs) Human Resources (HR) Philips General Procurement Travel Philips People Services International Mobility International SOS Travel incident response protocol Annexes Travel Risk Levels Evacuation Protocol Privacy Notice

3 Version History Author Version Reviewer Review Date Charlotte Taffijn (FICS) 0.1 Machiel toe Water (FICS) 15 Feb 2012 Charlotte Taffijn (FICS) 0.2 Marion Princen (PGP) 16 March 2012 Charlotte Taffijn (FICS) 0.3 Ross O Reilly (Intl.SOS) 2 Aug 2012 Charlotte Taffijn (FICS) 0.4 Caroline Visser (FICS) 9 Oct 2012 Charlotte Taffijn (FICS) 0.5 Jap Jongedijk (Group Legal) 16 Nov 2012 Charlotte Taffijn (FICS) 0.6 Hermine Rosulek (PPS IM) 6 Feb 2013 Nicole Eygelshoven (PPS IM) Charlotte Taffijn (FICS) 0.7 Ronald de Jong (CML) 25 Aug 2013 Charlotte Taffijn (FICS) 0.8 Caroline Visser (FICS) 2 Sep 2013 Charlotte Taffijn (FICS) 0.9 Jap Jongedijk (Group Legal) 2 Sep 2013 Machiel toe Water (FICS) 0.10 Caroline Visser (FICS) 22 Oct 2013 Machiel toe Water (FICS) 1.0 Executive Committee 7 Jan 2014 Philip van Notten (RMM&BDs) 1.1 Caroline Visser (RMM&BDs) 14 April

4 List of acronyms CM = Country Manager CML = Chief Market Leader DMA = Decision Making Authority FICS = Fraud Investigations and Compliance Services HR = Human Resources GCMT = Group Crisis Management Team LCMT = Local Crisis Management Team Intl.SOS = International SOS PGP = Philips General Procurement IM = Philips International Mobility Procurement IMS = Procurement Indirect Material and Services ML = Market Leader RMM&BDs = Risk Management Markets & Business Development support HoRM = Head of Risk Management in the Market (part of RMM&BDs team) 4

5 1. Introduction To ensure the health and well-being of our employees during their stay abroad, Philips partnered with International SOS ( Intl SOS ), the leading medical assistance, international healthcare and security assistance company, to develop the Philips Travel Risk Program. This Program includes medical and security services available for all Philips travelers and expats. Philips Duty of Care statement: Philips meets its Duty of Care responsibility to its international travelers and expats by providing them with: 1.1 Purpose Access to information, equipment, training relating to potential security and medical risks they could encounter prior to and during their assignment; A documented procedure in place to ensure that security and medical risks have been fully considered and appropriate mitigation measures have been taken; Access to relevant security, medical and legal services in the event of an emergency. The purpose of this Travel Risk Policy ( Policy ) is to establish a Philips-wide procedure with respect to travel risk-related matters or potentially hazardous situations that could affect the safety of all Philips travelers and expatriates and/or the reputation of Philips. The intent of this Policy is to ensure that travelers and expats successfully complete all of the predefined risk mitigation requirements to minimize travel-related risk, as well as ensure proper mitigation in case of a travel incident. 1.2 Scope Covered by this Policy are: Business travelers: Any Philips traveler who has declared to be on a work-related assignment on behalf of Philips outside his/her home country or his/her country of assignment; Expatriates: Any Philips employee who has been posted abroad under the conditions as defined in the Philips Expatriate Policy and Terms and Conditions and their accompanying dependents; Dependents: Accompanying primary dependents of Philips expatriates. Not covered by this Policy are: Local employees (unless a traveler); International Hires with a local employment agreement; Local Cross Border Commuters: Philips employees which are or will go on an international assignment to work abroad permanently, meaning that their (new) country of employment is not covered by this Policy. Conversely, should these employees travel for business purposes outside their (new) country of employment, they are covered by this Policy. Private travel of employees and expats outside their country of assignment; Travel from home to work within the same country; 5

6 Travel arranged by a staff member as part of travel for an official mission, but advised against by the Country Manager ( CM ) of the host country or the Market Leader ( ML ), or given the situation when the CM or ML have not been timely informed of that travel. 1.3 Decision-Making Authority (DMA) The Country Manager ( CM ) of the host country is responsible for travel-related decision-making, following a travel incident within that country. If necessary, this responsibility can be escalated to the relevant Market Leader ( ML ) or the Chief Market Leader ( CML ). The ML and CML will always be notified by the CM about a decision and, if applicable, the escalation thereof. In the event that CM or ML disagrees with the travel advice provided by Intl.SOS for a particular country, the decision requires approval of the CML as final decision maker. Please see section 3.2 for a full description of the different roles and responsibilities, including a response protocol to be used as guidance should a travel incident occur. 1.4 Travel to High and Extreme travel risk countries 1 In case of travel to High and Extreme risk countries 2 all alternatives should be explored beforehand, such as postponing the travel, conducting a videoconference, and/or changing the venue for events. If, however, travel is still required, the following applies: Approval: Extreme Risk countries: As a rule, Philips will not authorize any travel to Extreme Risk countries. For exceptions, a written request shall be submitted per to the ML for approval. The ML may approve such travel on an exceptional basis. High Risk countries: Travel to High Risk countries should be considered on a case by case basis. Prior formal security clearance should be required from the CM or ML of the host country, following a comprehensive review of the risks faced by the travelers and the assurance that the necessary measures to minimize risks have been taken. The CM/ML has the authority to deny the initial travel request if he/she considers this to be appropriate in view of the current situation in his/her country in consultation with Intl.SOS. All travel to Insignificant, Low and Medium risk areas may proceed without the need for a security clearance prior to travel. Philips employees wishing to travel to sanctioned and/or embargoed countries (e.g. Iran, Sudan, Syria, North Korea, Cuba, Crimea region of Ukraine 3 ) need prior approval from their own ML and the ML of the market where the country is located. Prior to travel, travelers must inform RMM&BDs about the travel itinerary by means of the RMM&BDs functional account: RMM_BDs@philips.com. In addition, travelers 1 This includes expatriates residence in their country of deployment. Expats may use all services under the Travel Risk program during their deployment. Besides this policy, information for expats is provided in the Philips Expatriate Policy and Terms and Conditions. 2 According to the latest Travel Risk Ratings as provided by International SOS 3 Please note that the list of sanctioned and/or embargoed countries is such subject to change. Please consult the Philips Corporate Export Control intranet page on sanctioned countries 6

7 to the sanctioned and/or embargoed countries must consult the local legal and/or export control responsible person in the organization prior to travel. Market management must ensure that there are specific standard operational rules in place to ensure compliance with the specific restrictions imposed under applicable sanctions laws and the Philips GBP Export Controls and Sanctions Policy. Various currencies, IT systems and travel services in Philips cannot (system block) or may not (legal requirement) be used when traveling to sanctioned and/or embargoed countries and local procedure for booking and expense reimbursement should be put in place. Consult Philips Legal Compliance, Corporate Export Controls website for additional guidance. 4 Preparation: Individual international travelers and expats are personally responsible to ensure that they meet the requirements of this Policy and are adequately prepared for travel, including having a good understanding of security/medical risks, laws and customs relevant to their destination(s). Part of that preparation includes reading information available in the Pre-Trip Advisory sent out via to the individual travelers, following travel bookings, as well as confirming that the traveler has read the Advisory by clicking the Compliance Tracker link. A pre-deployment security briefing is compulsory for ex-pats and can be requested at Philips International Mobility. All travel shall be booked via the contracted Philips travel agent and Online Booking Tools where available 5. In this way, Philips will be able to contact all travelers and expats in the event of an emergency. Assistance: Travelers and expats shall be assisted in whatever capacity deemed most appropriate. In order to ensure that they receive the best available pre-travel advice and emergency assistance in the event of a situation arising which may pose a threat to their overall security and safety. In order to ensure that Philips is best placed to assist the traveler, the latter is strongly encouraged to check-in via the Assistance App on his/her phone. 1.5 Policy Ownership and Review This Policy document shall be owned exclusively by Philips Human Resources Management (hereinafter: HRM ). The Policy will be reviewed annually or when significant changes in the internal organization or external environment occur. The review shall be a consultative review including all the stakeholders mentioned in the roles and responsibilities in this Policy. The review shall be coordinated by Risk Management Markets & Business Development support ( RMM&BDs ). If RMM&BDs identifies additional actions requiring further follow-up, alignment with the above-mentioned stakeholders will take place, as appropriate. 4 Please consult the Philips Corporate Export Control intranet page on sanctioned countries 5 Please consult the Philips Travel Policy regarding bookings made via designated travel agents 7

8 2 Travel Risk Services 2.1 Country Briefings All travelers and expats are encouraged to read the country briefings for their destination available on the Philips Travel Risk Portal 6 or via the Intl.SOS Assistance App 7 available for both a personal and a work smartphone. Intl.SOS also offers the possibility to access travel alerts as well as extensive information on their destination location. Pre-travel country medical guides and travel security advice are available for travels to any country of any risk rating, through the following channels and using the Philips membership #30BYCA000019: Call the Philips dedicated 24/7 hotline (+33 (0) ) to ask Intl.SOS for any pre-trip advice or information, such as regarding any required vaccinations, medications, addressing any travel security concerns etc. The Philips Travel Risk Portal, which offers the latest information on the destination country regarding travel, medical and security risk The Intl.SOS Assistance App available on any smartphone (personal or work) 2.2 Travel Tracking All Philips business travels are tracked electronically in the Travel Tracker system, via data feeds from designated Philips travel agents connected to the system (through Intl.SOS). Travel booked via a non- Philips-designated agent is not registered in the Travel Tracker. Travel tracking serves the following purposes: Allows Intl.SOS to send special alerts and security updates to travelers and expats should the situation deteriorate at their destination Allows RMM&BDs to send important messages to travelers (such as those regarding specific travel advice, or regarding a travel ban/restriction) Given a local travel/security incident, a list of travelers currently on the ground is readily available to check for their safety and wellbeing Privacy Notice: All travel-related data collected by Intl.SOS concerning Philips employees is protected by Philips Privacy Rules and Intl.SOS s Data Protection Policy. Please see Annex 5.3 for the detailed Privacy Notice. 2.3 Travel of Dependents Recognized primary dependents of expats are covered by this Policy and must therefore strictly adhere to the same security and risk mitigation procedures that apply to the Philips staff on mission. These persons must, therefore, also be registered with Philips International Mobility (IM) so that the 6 log-in using the Philips-wide membership number 30BYCA log-in using the Philips-wide membership number 30BYCA

9 information can be entered into the Travel Tracker (see section 2.2. above), and safety and security assistance rendered if required. Spouses and recognized primary dependents and/or companions of business travelers are not covered, with the exception that he or she has explicit approval of the Executive Committee. 3 Roles and Responsibilities 3.1 Travelers and Expats Travelers and expats have a Duty of Loyalty towards Philips as their employer, and are therefore individually responsible for the following: Reviewing the country briefings provided on the Travel Risk Portal (see section 2.1), familiarizing themselves with the risk rating of their country destination; Contacting Intl. SOS and the CM when in doubt and/or in the need for further information; Seeking authorization of CM/ML before traveling to High and Extreme Risk areas, well in advance of the planned mission; Complying with the recommendations and advice provided by the CM and Intl. SOS in the case of travel to High and Extreme Risk areas; Maintaining required security awareness and applying good judgment and common sense while travelling abroad, as each traveler is ultimately responsible for his/her own safety; Report the handling and conclusion of travel incidents to their respective HR manager. 3.2 Market Leaders (MLs) ML has the following responsibilities: Act as decision maker with regards to possible actions and costs which can be undertaken in case of a local travel incident 8. The responsibility can be delegated to a Country Manager (CM), if considered appropriate. Ensure that the Policy is understood, deployed and strictly adhered to in their respective countries/market; Decide whether planned travel to High and Extreme risk countries should proceed in view of the risks incurred and taking into account the travel experience and the profile of the staff member(s) concerned after consulting with Intl.SOS; Ensure that measures recommended by Intl.SOS (as well as any other additional required ones) are implemented for the travelers to High and Extreme risk countries; In the event of disagreeing with the country risk rating provided by Intl.SOS 9, the CM/ML must request for approval for travel from the Chief Market Leader ( CML ) 10 ; The ultimate responsibility ensuring that their visitors and staff are adequately prepared to travel; 8 Please find the Travel Incident Response Protocol in Section 4 9 In the sense that the CM/ML believes the risk rating should be lower (for example, from a high risk to a medium risk) and (extraordinary) measures to be taken by the traveler as advised by Intl.SOS are not necessary. 10 Only concerning High and Extreme Risk countries as assessed by Intl.SOS 9

10 Ensure that all options have been explored, such as postponing the travel and/or changing venue for events, before security clearance is granted; Inform CML in case of a travel risk incident if severity justifies such; 3.3 Risk Management Markets & Business Development support (RMM&BDs) RMM&BDs has the responsibility for the following: Act as the primary contact point with Intl.SOS; Act as the primary interface between Intl.SOS and security professionals abroad concerning security issues affecting Philips travelers and expats; Inform the Head of Philips International Mobility and the Manager Philips International Mobility (IM) in case an incident occurs with an expat; Advise the Chairman of the Global Crisis Management Team ( GCMT ), in function of the Coordinator of the GCMT, of any situation/incident that may require the extraordinary convening of the GCMT; Implement a focused awareness strategy to inform travelers of the level of assistance they will be provided when they travel abroad; Inform CML about possible advice provided to CM/ML in consultation with Intl.SOS; Review the travel incidents handling by Intl.SOS; Respond to travel incidents 11 with the support of RMM&BDs Heads of Risk Management in the Markets and the Local Crisis Management coordinators ( LCMT ). 3.4 Human Resources (HR) HR is responsible for the following: Owner of the Policy; Make this Policy accessible to all Philips employees and ensure effective deployment; To act as an Authorized Person (APs) in each Market, by approving costs incurred in case of assistance provided by International SOS to a Philips traveler in each Market; In case of a major revision, the updated Policy shall be published with the major changes highlighted or re-communicated to all stakeholders. 3.5 Philips Procurement IMS Philips Procurement IMS is responsible for the following: Ensure a relationship between the preferred global travel agency and Intl.SOS is established in order for employee travel data to be transferred to Intl.SOS in a timely manner, and later integrated in Travel Tracker; Should the CM/ML decide to implement a travel ban or restriction to a High/Extreme Risk country, to instruct the preferred global travel agencies and booking tool providers to inform travelers of the same. 11 Please find the Travel Incident Response Protocol in Section 4 10

11 3.6 Philips International Mobility Philips IM is responsible for the following: Inform expats about the available services provided by Intl.SOS. Inform Intl.SOS about the Philips expat population by providing (monthly) overview reports. 3.7 International SOS Intl.SOS is contractually responsible for the following: Act as primary interface between Philips travelers and expats, CM and RMM&BDs for the purpose of requesting and receiving security advice; Supervise and record in Philips travel tracking system details of travelers booked through the approved Philips travel agents; Provide advice to CM and RMM&BDs relating to travel risk issues, as necessary; Provide security briefings to travelers and expats, as necessary; Contact the designated insurance company, as agreed under the direct billing agreement. 4 Travel incident response protocol Should a travel incident occur 12 the decision-making processes are guided by the priority to ensure the immediate safety of employees. This may require that some employees are provided with medical assistance, moved to a safer location, or that a security escort is coordinated. Intl.SOS should always be contacted in the first instance if this service is covered. Please find below a RACI 13 matrix concerning the response in case of a travel incident: Actions Receive Intl.SOS special advisory (alert), check standing travel advice and any other recommendations 17 Extract list of (international & domestic) travelers from Travel Tracker (on the ground and upcoming) 18 Communicate updated list of travelers to CL/ML and LCMT coordinator CM/ML LCMT coordinator 14 HoRM 15 RMM&BDs SVAL 16 - R A RA C I I RA - 12 Examples of travel incidents include earthquakes, flooding, terrorist attacks etc. 13 RACI matrix Mapping of who is responsible and accountable for an action, and who should be consulted and informed 14 Local Crisis Management Team coordinator 15 Head of Risk Management in the Market (part of the RMM&BDs team) 16 Single Value Added Layer 17 The LCMT coordinator and the HoRM to subscribe to the special advisories issued by International SOS in case of (major) travel incidents/crises 18 Philips employees who book their trips out of Philips Travel Policy will not appear in Travel Tracker with the risk of remaining invisible to the Philips crisis management organization 11

12 Check whether all relevant Philips local employees and expats are well and safe. Check whether all international Philips travelers are well and safe (through Travel Tracker and SMS) Decide on instating a travel ban or restriction Inform Chief Market Leader if severity justifies Communicate travel ban/restriction to upcoming Philips international travelers (through Travel Tracker) Communicate travel ban/restriction to all Philips designated travel agents Update Philips Travel Risk Portal and Pre- Trip Advisories with travel ban/restriction Monitor local situation to assess when to lift the travel ban / restriction Periodically assess whether to maintain or lift the travel ban / restriction (then follow steps 10 and 11) I RA I I I I RA C RA C C I RA I I I I I RA C I I I RA I I I RA - R A - RA C C I 5 Annexes 5.1 Travel Risk Levels The country-specific travel risk rating used by Philips evaluates the risks which could potentially harm Philips travelers. The following risk levels are defined by Intl.SOS for each country, and available on Philips Travel Risk Portal (unless the CM or ML disagrees with this risk level): Security Risks: Insignificant Risk: There is virtually no political violence or civil unrest and no significant sectarian, communal, racial or targeted violence against foreigners. There is no recent history of terrorism. The authorities maintain effective security and emergency services and infrastructure is sound. Transport services are typically of a high standard with good safety records and only occasional travel disruption. Industrial action impacting on essential services is rare and the government has the proven capacity to manage major events, such as strikes, with minimal impact to personnel. Low Risk: These countries or areas have low violent crime rates and are generally free of racial, sectarian or political violence or civil unrest. Terrorist organizations have only limited operational capabilities and acts of terrorism are extremely rare. Industrial action and transport disruption are typically infrequent and the government has the capacity to minimize the effect on travelers and expats. Travelers and expats face few problems and are unlikely to be directly targeted or severely disrupted. Commonsense precautions help minimize associated risks. 12

13 Medium Risk: Travelers and expats may face a risk from communal, sectarian or racial violence. Violent crime rates are likely to impact on foreigners as well as the local population. There are infrastructural weaknesses and inadequacies in the security and emergency services. Industrial action is not uncommon and can impact upon the traveler and expatriate. Transport services are likely to be subject to periodic disruption and safety records are inconsistent. Increased vigilance is warranted for travel or expatriation. High Risk: Protests are frequently violent and may target or disrupt foreigners. There may be a high level of incidental risk to travelers and expats from terrorism or insurgency. Communal, sectarian or racial violence is common and foreigners may be directly targeted. Violent crime rates are typically high and scams targeting foreigners are common and often have police complicity. Infrastructure and internal security and emergency services are poor and there may be regular abuses of due legal process. Extreme Risk: There is a serious threat of violent targeted attacks against travelers and expats by terrorists, insurgents, sectarian, criminal or other extremist groups. Government and transport services are typically severely degraded or non-existent. Foreigners are likely to have no access to significant parts of the country. Armed escort and stringent preventive security precautions are essential and may not be sufficient to prevent serious injury, kidnap or loss of life. 5.2 Evacuation Protocol During times of a severe incident or crisis that potentially impacts the safety of our travelers and expats (and dependents), a decision may be reached whereby an evacuation is required. All travelers are obligated to abide by the decision of the ML who takes the decision in consultation with the CM, RMM&BDs and Intl.SOS. In the event that a traveler disagrees with the decision taken by the ML, the decision must be escalated to the CML or the Head of RMM&BDs acting as his/her delegate. If and when an employee no longer feels comfortable with the security situation, despite additional risk mitigation measures being put in place, the employee has the right to depart earlier at his/her and responsibility. 5.3 Privacy Notice Type of data collected The data that International SOS receives includes the following related to Philips travelers and expats: Full name Telephone number Date of birth Travel data (flights, dates, hotel) Third parties International SOS may disclose your data to other companies involved in providing the medical and travel security assistance (for example, IT and communication service providers, data processing companies and 13

14 other parties bearing a necessary relationship to your medical and travel security assistance). Any other disclosures to third parties will only be made when required by law. Philips requires these service providers to provide a comparable level of protection to your personal data as Philips provides, to only process your personal data for the purposes mentioned above, to have access to the minimum amount of data they need to deliver a specific service. If Philips transfers your data or allows a third party to transfer your personal data, we will take steps to protect your privacy rights through the use of contractual arrangements or other means, which will provide a comparable level of protection while the information is being processed by our third parties. Data storage Your personal data will be hosted and stored by International SOS on its data centers located in the EU (France). Data security Philips recognizes its responsibility to protect the information that is entrusted to us. Philips has instructed International SOS to implement appropriate technical and organizational measures to protect your data. Access Philips has instructed International SOS to provide access only to individuals who process personal data as part of their respective roles or responsibilities shall be authorized and provided access to your personal data, and only to the extent necessary to serve the applicable business purposes and in the performance of their duties. Employee rights Employees have the right to access their personal data. If the personal data are incorrect, incomplete or not processed, the employee has certain rights to have his personal data rectified, deleted or blocked, in accordance with applicable laws. Please contact Risk Management Markets & Business Development support if you have questions or concerns regarding (the processing of) your personal data by Intl.SOS. Changes to this Privacy Notice This privacy notice was last updated on This Privacy Notice may be changed from time to time without notice. Therefore, we encourage you to check back often to learn about those changes. 14