Whistleblowing guidelines

1. Introduction – what is whistleblowing, and why is it important?

LLENTAB Group strives to achieve transparency and a high level of business ethics. Our employees are the most important source of insight for revealing possible misconduct that needs to be addressed.

Our whistleblowing service offers a possibility to alert the company/organization about suspicions of misconduct in confidence. It is an important tool for reducing risks and maintaining trust in our operations by enabling us to detect and act on possible misconduct at an early stage.

Whistleblowing can be done openly or anonymously.

The purpose of these Whistleblowing guidelines is to encourage employees (and possibly external stakeholders) to blow the whistle on suspected misconduct without any risk of retaliation, as well as to ensure an appropriate investigation process.

2. When to blow the whistle?

The whistleblowing service can be used to alert us about serious risks affecting individuals, our company/organization, society, or the environment.

The processing may only refer to data about serious improprieties concerning:

  • accounting, internal accounting controls, auditing matters, fight against bribery, banking- and financial crime, or
  • other serious improprieties concerning the company’s or the group’s vital interests or the life or health of individual persons, for instance, serious environmental crimes, major deficiencies that regard the security at the place of work, and very serious forms of discrimination or harassment.

For issues relating to dissatisfaction in the workplace or related matters, for example, employees (and any other stakeholders) are asked to contact their supervisor or manager, as these issues cannot be investigated in the scope of the whistleblowing.

A person who blows the whistle does not need to have firm evidence for expressing a suspicion. However, deliberate reporting of false or malicious information is forbidden. Abuse of the whistleblowing service is a serious disciplinary offense.

Please note there are restrictions on the use of a whistleblowing service in certain countries.

3. How to blow the whistle?

There are different ways to raise a concern:

4. The investigation process

Investigation

All messages are treated seriously and by these Whistle-blowing guidelines.

  • No one will attempt to identify the whistleblower.
  • Whistleblowing messages are handled confidentially by the parties involved.

Whistleblower protection in the case of non-anonymous whistleblowing

A person expressing genuine suspicion or misgiving according to these guidelines will not be at risk of losing their job or suffering any form of sanctions or personal disadvantages as a result. It does not matter if the whistleblower is mistaken if he or she is acting in good faith.

Subject to considerations of the privacy of those against whom allegations have been made, and any other issues of confidentiality, a non-anonymous whistleblower will be kept informed of the outcomes of the investigation into the allegations.

In cases of alleged criminal offenses, the whistleblower will be informed that his/her identity may need to be disclosed during judicial proceedings.

To ensure independence and confidentiality, all reports are received by an external actor who reviews the report and forwards the case to appointed case managers at LLENTAB. At the same time, the external actor ensures that cases are not sent to case managers who may be affected by the case. If external expertise is needed, investigations can also be carried out by an external actor with extensive experience in whistleblower cases and related investigations. No information about you as a notifier will be disclosed unless you have given your consent to this. You choose for yourself whether you want to be completely anonymous to the independent actor’s investigators or whether you want to say who you are.

Deletion of data

Personal data included in a whistleblowing message and investigation documentation is deleted when the investigation is complete, except for when personal data must be maintained according to other applicable laws. Deletion is carried out 30 days after completion of the investigation. Investigation documentation and whistleblower messages that are archived should be anonymised; they should not include personal data through which persons can be directly or indirectly identified.

5. Legal basis of the Whistleblowing guidelines

This policy is based on the EU General Data Protection Regulation and guidelines on whistleblowing.

6. Transfer of personal data outside the EEA

All data is stored within the EU. There is a general prohibition on the transfer of personal data out of the European Economic Area (EEA) unless specific mechanisms are used to protect data.

NB. The scope of this Whistleblowing guideline does not include the potential transfer of personal data from the EEA to affiliates located outside the EEA.