Whistleblower policy for A/S Saeby Fiske-Industri
A/S Saeby Fiske-Industri encourages an open corporate culture in which everyone can freely report suspicions of irregularities or illegal behavior.
Employees, the management, members of the board of directors, customers, grant recipients, partners and A/S Saeby Fiske-Industri stakeholders are thus included in the whistleblower scheme.
The scheme means that employees can make anonymous reports in case of reasonable suspicion of serious and reprehensible conditions and illegalities. The system ensures that such reports are treated seriously and provides reassurance that any person who, in good faith, reports a serious suspicion will be protected from retaliation and the like.
What conditions can be reported?
The scheme can only be used to report illegal behavior or negligence, as well as other serious and sensitive matters.
The purpose of the whistleblower scheme is to make it easier for A/S Saeby Fiske-Industri’s employees and its stakeholders to:
- speak out about illegal or criticisable situations.
- protect individuals who make use of the whistleblower scheme.
- detect errors and negligence.
The whistleblower scheme is a supplement to A/S Saeby Fiske-Industri’s direct and daily internal communication about errors, unsatisfactory situations etc. Problems should thus be initially brought up with, for example, the employee’s line manager, staff representative or the management directly.
Conditions that can be reported may, for example, be justified suspicion of:
Fraud/Economic crime
- Economic crime such as embezzlement bribery, fraud, forgery and theft of goods and inventory, etc.
- Irregularities regarding accounting and auditing.
- Violation of competition act (pricing, exchange of price sensitive information)
Food safety
- Conditions that have a negative impact on food safety, product integrity, quality and legality.
Production, in general
- Submission of incorrect or misleading information to public authorities.
- Serious threats to the environment and safety.
Human Resources
- Physical violence, sexual abuse and health
It is assumed an individual filing a whistleblower report is knowledgeable of, or has a reasonable suspicion of, one of the above-mentioned offenses being committed.
Issues related to an individual’s employment, such as absenteeism, office conflicts, smoking, alcohol consumption, clothing, salary etc., as well as matters that are not serious, should not be reported on using the whistleblower portal; such matters should be brought up with a manager, the Human Resources department, the staff representative or the like.
To the extent possible, the report must be accompanied by electronic versions of relevant documents.
How is a report made via the Whistleblower scheme?
Reports must be filed electronically by completing and submitting an online questionnaire, which is available here: https://saeby.whistleportal.net
It is not possible to file a report in any other way; reports typically contain confidential information that may not be sent unencrypted over the open internet. Reports can be in Danish and English.
A/S Saeby Fiske-Industri does not tolerate any form of retaliation or punishment of persons who in good faith report or assist A/S Saeby Fiske-Industri in investigating violations in accordance with the whistleblower policy. A/S Saeby Fiske-Industri does not allow any sanctions that could harm the whistleblower.
Reporting in bad faith via the whistleblower scheme for the purpose of harassing or harming other employees will be subject to sanction and may be faced with employment law consequences.
How the reports are being handled
All information is treated confidentially and with discretion.
In the event a report is filed anonymously, the person filing the report should leave out any form of contact information (name, e-mail address, telephone number etc.), and remove all metadata from files attached as documentation, for example names that are to remain anonymous. The person filing the report should not provide any information that can reveal their identity.
Should an enquiry be undertaken by an external body, such as the police, A/S Saeby Fiske-Industri may be forced to disclose the identity of the individual filing the report, if A/S Saeby Fiske-Industri is aware of it.
If the information is reported using a network belonging to A/S Saeby Fiske-Industri or another monitored network, visits to the whistleblower portal may be registered internally as part of the routine logging of user activities. This risk can be avoided by entering the web address in a browser on a public or personally owned computer that is not connected to a monitored network.
The whistleblower portal is designed to prevent or restrict the storage of information when visiting and using the portal. The whistleblower portal supports the use of TOR browsers, which, when used to visit the whistleblower portal, can provide the highest possible level of anonymity. https://www.torproject.org/download
Advisory and accounting firm BDO has been engaged by A/S Saeby Fiske-Industri as data processor. BDO provides and administers the whistleblower portal.
The reports filed via the whistleblower portal are accessed by a limited number of BDO employees entrusted to receive and register the reports and forward them to the management of A/S Saeby Fiske-Industri. If the report relates to the management of A/S Saeby Fiske-Industri, the report is forwarded to the chair of A/S Saeby Fiske-Industri.
An initial review of the report will be made to assess whether it falls within the framework of the whistleblower scheme, whether the matter should be looked into further or whether the report can be dismissed as manifestly unfounded (this would be the case if, for example, the report is filed by, or concerns issues related to, a person to whom this whistleblower scheme does not apply).
If the allegations in the report cannot be immediately dismissed, an enquiry into the matter will be opened. The enquiry will involve external assistance as necessary. This could be in the form of legal or other types of consultants.
How personal data is handled.
All processing of personal data submitted in connection a whistleblower report (to include collection, storage and any transmission) is subject to applicable data-protection regulations.
A/S Saeby Fiske-Industry has real and legitimate grounds for processing personal data submitted in a report, and the processing is considered to override the interests of the individual to whom the data relates. The processing is thus carried out on the basis of the legitimate interests rule in Article 6 (1) (f) of the General Data Protection Regulation.
How reported cases are being handled.
A person filing a whistleblower report anonymously can follow its status using a 16-digit key code that is displayed after the report is filed via the whistleblower portal.
A person filing a whistleblower report can subsequently communicate anonymously with BDO using the 16-digit key code. The communication channel is used to acknowledge receipt of the report, and it provides an opportunity to ask any additional questions of the person filing the report without the individual having to reveal their identity. This can help ensure that there is sufficient information to assess the allegations made in the report.
In the event that the report was filed anonymously, the communication channel will likewise be used to communicate any decision about the report to the person who filed it. In the event a report is filed anonymously, the following deadlines for replying via the whistleblower portal apply:
- Receipt of the report is acknowledged within seven days.
- A review of the report is initiated as soon as possible; the aim is for the review to be completed within three months.
- The findings of the review are communicated via the anonymous communication channel to the person who filed the report.
- As a rule, all reports are deleted from the whistleblower portal within 90 days of their filing date unless the deadline is manually extended by the recipient.
- The person filing the report can access the status of the review via the whistleblower portal using the 16-digit key code until the report is deleted from the portal. However, the person filing the report has full access for one year from the time of filing the report.
The person to whom the reported information relates.
Unless there are special, significant and justified investigative considerations, the person to whom the reported information relates will be notified when a report has been received and in the event an enquiry is opened.
Rights
Individuals who submit information under the terms of the whistleblower scheme will, as a rule, be informed of the report’s status, as well as the outcome of the initial assessment and the enquiry into the allegations, if one is opened.
Deletion of data
If the report does not fall within the scope of the whistleblower scheme, or if the report is unfounded, the personal data it contains will be deleted immediately.
Personal data are also deleted when it is no longer necessary to store them, such as after the conclusion of an enquiry.
Reports are generally deleted from the whistleblower portal within 90 days of their filing unless the deadline is manually extended by the recipient.
The general guidelines for deletion of data apply otherwise. If the information collected leads to a disciplinary sanction being imposed on an employee, or if it is otherwise relevant and necessary to continue to store information about the employee, the information will be stored in the individual’s HR file.
Questions
All questions regarding this whistleblower scheme can be directed to A/S Saeby Fiske-Industri CEO in writing cbc@saeby.com or by telephone Tel: +45 98 46 10 66.
