Policy Whistleblowing

Background

Whistleblowing is used to draw attention to anomaly and the term has come to use for both alarming media and when you acknowledge problems internally.

Kjell Group has a whistleblowing system where employees can anonymously acknowledge the organization on anomaly within the company. The whistleblowing system is held by an extern part to rule out any possibility to trace the informer’s identity. Information about the extern part can be found on the intranet. Since it is not possible to identify the informer behind a report, it is not possible to verify if the person is an employee within the organization either. All reports will be considered.

Purpose

The system shall clarify everyone’s responsibility to together acknowledge problems and areas where we as an organization or our employees do not follow rules, or fully go by our guidelines. The system will also be a reminder for the organizations responsibility to clarify which rules applies and what is expected from employees. All in all, shall the whistleblowing strengthen a culture where problems are considered and discussed.

We have high hopes that all employees feel comfortable enough to openly discuss problems. But the possibility to anonymously report a tip is made to reassure that no consequences will follow reporting misconducts.

The whistleblowing function shall be seen as a compliment rather than replacement for an open debate climate. Normally, you should turn to your closest boss or a person in the administration that you trust.

Kjell Group has completely forbidden retaliation. That means that we have a zero tolerance for punishing a person for reporting anomaly – whether real or perceived – if the act was made with good intentions. However, intentional mudslinging or rumor spreading will not be tolerated.

The extern part is meant for serious violations, such as crimes against the local and/or European law system and matters that are of public interest. These matters will be dealt with in the whistleblower system’s defined examination process. Other matters will be submitted to appropriate part.

About the system

It is important that we with transparency and clarity protect the user’s anonymity for the system to be trustworthy. It is also important to help informers to leave as good information as possible. A few aspects that Kjell Group have special consideration for are:

• Independent process of matters. Matters that are qualified as whistleblowing matters, will be dealt with by an especially appointed group. No unauthorized has access to the information.
• Information to user. As an informer you shall know in what way you are protected technically and what you yourself must think of to not give out too much information. This could be about files with user data, risks with reporting from your workplaces’ network or the risk of exposing yourself by the way you express yourself.
• Data storage. Vi have chosen a provider with their own dedicated servers, placed in Sweden. Processed matters will be deleted from the system so that no information is saved longer than needed.
• Handling of information. No sensitive data should be sent via e-mail, therefore personal log in is always needed to access and process matters.
• Reporting quality. Clear questionnaires help the informer to give complete information which gives even better investigation of the matters. As a complement, there is the possibility to anonymously correspond with the informer.
• Since communication by phone becomes more and more usual, it is given that the report website is altered for phone usage. What is even better with this, is that phone usage often lies outside the workplaces’ network and is therefore a better alternative than the workplaces’ computer during working hours. There is also a possibility to leave information over phone.

About the process of matters

Matters are processed by an especially appointed group. Investigation and potential recommendation for action or further handling will be presented to Kjell Group management team.

Matters that fall outside of the system’s purpose will not be considered a whistleblowing matter but will be sent over to a relevant employee at Kjell Group.

People who are pointed out in a matter will be informed about the ongoing investigation as soon as it is possible in regard for the investigation. Whoever stands behind the report will however not be informed, regardless of if it is known by the investigator.

After the process, the matter will be deleted from the database. If the matter needs further investigation, information will be saved outside of the database. The information will be destroyed or anonymized as soon as it is possible regarding the investigation.

If an informer chose to be open about its identity, will his or her identity still exclusively be available for the group that is chosen to handle the whistleblowing matters. Exceptionally, ff the matter result in a criminal investigation, the informer could be needed as a witness.

Evaluation and improvements

For the whistleblowing system to reach its goal, regular evaluations of how the extern part is used, if concerned people know about the extern part, if the kind of matters agree with the system’s purpose and if routines for the handling works as planned, will be made.