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Information for whistleblower

Who can blow whistle?

All employees, temporary workers, freelancers, volunteers, interns, and company shareholders who, in the course of their work or duties, have obtained information about law violations by the company can make reports.

What can be reported?

Through this reporting channel, you can report crimes, violations, or misconduct or suspicions of them. This may include, or example, bribery, corruption, money laundering, the shadow economy, violations of competition law, violations of data protection law, actions contrary to product or food legislation, pertaining to legal areas. The channel is not intended for reporting issues related to inappropriate behavior or violations of equality.

To receive whistleblower protection, you are not required to have evidence of the reported violation, but your report must be made in good faith and based on facts or circumstances that, on the balance of probabilities, give reason to suspect that a violation has occurred. If your report concerns something else, it will not be further processed. However, you will always be informed of the result of the preliminary assessment, even if it does not lead to further actions.

Processing and investigating of the reports and obtaining protection applies to the legal areas specified in the Whistleblowing Directive, which are:

  • Public procurement (excluding defence and security spending)
  • Financial services and products, prevention of money laundering and terrorist financing
  • Product safety and conformity
  • Traffic safety
  • Environmental protection
  • Radiation and nuclear safety
  • Food and animal feed safety and animal health and welfare
  • Public health
  • Consumer protection
  • Privacy and personal data protection and network and information systems security

Processing and investigation of reports

The individuals designated by the company to process reports are bound by confidentiality and impartiality. Necessary measures are taken promptly from the receipt of the reports to the initiation of actions, and the whistleblower is informed in accordance with legal obligations. In a potential investigation, employees may be interviewed to verify the accuracy of the reports. Employees are required to keep confidential all information obtained during the investigation. If necessary, external individuals may be involved in the investigation, and confidentiality also applies to them.

Processors can reject a report if it does not concern provisions according to the directive and national law, if the guidance is not considered, or if the report has already been processed. A processor may also reject a report if it is not made in good faith or if it is made with malicious intent, if there is insufficient information available to initiate an investigation, or if the accuracy of the provided information cannot be determined.

Protection of the whistleblower and prohibition of retaliation

No retaliatory actions shall be taken against a whistleblower who makes a proper and lawful report due to the reporting or disclosure of information regarding a violation. It is also prohibited to engage in conduct intended to prevent the reporting or disclosure of information regarding a violation.

Prohibited retaliatory actions include diminishing the terms of employment or termination of the employment of an individual in an employment or official relationship, placing the person on leave, treating them unfavorably, or subjecting them to other negative consequences because they have reported or disclosed information regarding a violation or participated in the investigation of the reported violation.

False reports

The whistleblower must act in good faith. If the whistleblower misuses the reporting procedure by deliberately making false or malicious claims, they commit a serious violation that may lead to labor law disciplinary actions, as well as potentially legal and criminal consequences.

Reporting to the Chancellor of Justice’s Office

You may also exceptionally report this directly to the Chancellor of Justice’s Office if the following conditions are met:

1) the organization does not have an internal reporting channel, or the whistleblower has not been given the opportunity to report through the internal reporting channel;
2) he whistleblower has a reasonable belief that no measures specified in Section 16 have been taken within the deadline set out in the second paragraph of that section based on the internal report;
3) the whistleblower has a reasonable belief that the violation cannot be effectively addressed based on the internal report; or
4) the whistleblower has a reasonable belief that they are at risk of retaliation due to the report.