Whistleblowing service and instructions

We want to do the right thing – whistleblowing service adopted throughout Delete Group

Our reliability and long-term success are based on ethically sustainable operations, the basic principles of which are recorded in our Code of Conduct.

It is important that each person reports suspected misconduct not in line with Delete’s Code of Conduct. This enables us to prevent or correct any misconduct.

Primarily, you are encouraged to contact a supervisor in our organisation. If you feel that you are unable to share your information openly, we provide you with this opportunity to anonymously express your concern via this channel.

To ensure anonymity, the reporting channel is managed by an external partner, Whistleblowing Centre.

The anonymous reporting channel can be found at https://report.whistleb.com/Delete

Further information:

Thank you for helping us be a company that promotes high business ethics.

 

Delete whistleblowing instructions

  1. Introduction

Our company strives to achieve and maintain an open business climate and high business ethics. Our employees are our most important source of insight for revealing possible misconduct that needs to be corrected.

Our whistleblowing service offers a possibility to report suspicions of misconduct in confidence. It is an early warning system to reduce risks and an important tool to foster high business ethics and maintain customer and public trust in our business. Whistleblowing can be made openly or anonymously.

The purpose of the Whistleblowing guidelines is to encourage employees to report matters without any risk of subsequent victimisation, discrimination or disadvantage, as well as to ensure an appropriate investigation process.

  1. When to blow the whistle?

Our whistleblowing service can help alert us to serious risks affecting individuals, our company, the society or the environment.

The Working Party under Article 29 of Directive 95/46/EC concludes that “whistleblowing schemes may be a useful mechanism to help a company or an organisation to monitor its compliance with rules and provisions relating to its corporate governance, in particular accounting, internal accounting controls, auditing matters, and provisions relating to the fight against bribery, banking and financial crime and criminal law.”

For issues relating to dissatisfaction at the workplace or misconduct on another topic, please contact your supervisor or manager.

A whistleblower does not need to have firm evidence of misconduct before expressing a misgiving. However, reports should be submitted honestly and in good faith. Abuse of the whistleblowing service, that is, deliberate reporting of false or malicious information is a serious offence and may result in further action.

  1. How to blow the whistle?

If an employee becomes aware of an issue or behaviour that is not in line with our company values and Code of Conduct, different ways of reporting are available:

  • Alternative 1. Report to your manager or another supervisor within our organisation
  • Alternative 2. Report to the company whistleblowing team:
    Janika Vilkman, General Counsel, Delete Group Oyj
    Janne Haaksluoto, HSEQ Manager, Delete Finland Oy
    Anne Sandström, HR Director, Delete Sweden AB
  • Alternative 3. Report anonymously through the whistleblowing service at: https://report.whistleb.com/Delete

Anonymous reporting (Alternative 3)

If an employee wishes to make an anonymous report, this is possible through the external whistleblowing channel. The channel is administrated by WhistleB, an impartial service provider that safeguards the anonymous handling of whistleblowing reports.  Neither our company nor WhistleB can identify or track the source of a report unless you provide contact details. WhistleB does not save metadata related to a whistleblower report and cannot track the IP address of a whistleblower. The service allows dialogue between the company whistleblowing team and an anonymous whistleblower.

  1. The investigation process

The whistleblowing team

Access to whistleblowing reports through our reporting channel is restricted to our whistleblowing team. Each team member is bound by a non-disclosure agreement which states that all whistleblowing cases must be handled confidentially. During the investigation process, the team may ask for information and expertise from other individuals. This is also carried out in confidence.

Receiving a report

All reports will be treated seriously. Upon receiving a report, the whistleblowing team decides whether to accept or decline the report.  If the report is accepted, appropriate measures for investigation will be taken. Please see Investigation below.

The whistleblowing team may decline to accept a report if:

  • the alleged misconduct is not reportable conduct under these whistleblowing instructions,
  • the report has not been made in good faith or is malicious,
  • there is insufficient information to allow for further investigation,
  • the matter of the report has already been solved.

If a report includes issues not covered by the scope of the whistleblowing instructions, the whistleblowing team should take appropriate actions to solve the problem.

Potentially intrusive information of a personal nature, such as health or political, sexual, or religious beliefs will not be included in an investigation.

Investigation

All accepted reports of alleged misconduct will be subject to an investigation in accordance with these whistleblowing instructions. The whistleblowing team determines the appropriate manner of investigation.

  • All whistleblowing reports are handled confidentially.
  • A report will not be investigated by someone who may be concerned or connected with the misgiving.
  • The whistleblowing team will, when needed, submit follow-up questions via the channel for anonymous reporting.
  • No one from the whistleblowing team, or anyone taking part in the investigation process, will attempt to identify the whistleblower by any means.

Whistleblower protection in the case of non-anonymous whistleblowing

If a whistleblower expresses genuine suspicion, the whistleblower will not be at risk of losing the job or suffer any form of sanctions or personal disadvantages as a result. It does not matter if the whistleblower is mistaken, provided that he or she is acting in good faith.

Unless it is inappropriate to do so, a non-anonymous whistleblower will be kept informed of the outcomes of the investigation into the allegations, subject to considerations of the privacy of those against whom allegations have been made and any other issues of confidentiality.

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

Protection of, and information to, a person specified in a whistleblower report

The rights of the individuals affected by complaints under this whistleblowing service are subject to the relevant data protection laws. Those affected will be entitled to the right to access data relating to themselves and to require amendments, should the information be incorrect, incomplete or out of date.

These rights are subject to any overriding safeguarding measures required to prevent the destruction of evidence or other obstructions to the processing and investigation of the report.

 Deletion of data

Personal data included in a whistleblowing report will be deleted when no longer needed for investigation and enforcement purposes and usually within one month (30 days) of completion of the investigation. Documentation from the investigation should be rendered anonymous. Name and address must be removed together with any other information which directly or, in conjunction with other data, indirectly could identify the person.

  1. Legal basis of the whistleblowing instructions

This policy is based on, and follows, the recommendation in the Article 29 Data Protection Working Party and Directive 95/46/EC (Data Protection Directive).

  1. Transferring personal data outside the EEA area

Transferring personal data outside the European Economic Area (EEA) is generally forbidden unless special action is taken to protect the data.

Note! The scope of these whistleblowing instructions does not include potential transfer of personal data from the EEA to affiliates located outside the EEA.