Whistleblower policy
The ABC Group’s whistleblower policy
The following policy has been prepared in collaboration with Deloitte, which also administers the ABC Group’s whistleblower scheme.
1. Purpose
This whistleblower policy applies to the ABC Group’s entities. The purpose of the whistleblower policy in the ABC Group is to encourage and support employees in reporting serious concerns about unlawful or unethical conduct that may harm our organisation, our employees, or the public.
2. Who is covered?
This policy applies to all current and former employees, including full-time, part-time, temporary employees and interns, as well as other individuals who are in contact with the ABC Group. The protection also applies to those who may be affected by whistleblowing, such as colleagues and relatives, in a work-related context.
3. What is whistleblowing?
Whistleblowing is when a person reports suspected irregularities, unlawful activities, or unethical behaviour within the organisation.
4. What can be reported?
Matters relating to breaches of EU law that fall within the scope of the European Parliament and Council Directive on the protection of persons who report breaches of EU law, and/or other serious criminal offences or other serious matters, may be reported, provided that these are not specifically exempted from the Act on the Protection of Whistleblowers, cf. Section 1 of the Act.
Violations, according to the Act on the Protection of Whistleblowers, are defined as actions or omissions that:
- Are illegal or constitute a serious violation of law or a serious matter in general, or
- Make it possible to circumvent the purpose of the rules that fall under the scope of the Act
Illegal and serious matters that can be reported via the whistleblower scheme include information about:
- Violation of criminal offenses
- Misuse of financial resources, theft, fraud, embezzlement, deception, and bribery
- Sexual harassment and other forms of gross harassment
The above are just examples. If you are unsure whether your observation should be reported or not, you are encouraged to do so. All inquiries are processed.
Less serious matters such as collaboration difficulties, bullying, or other minor offenses should not be reported via the whistleblower scheme but can be reported via the normal communication channels. If such matters are reported to the whistleblower scheme, the report will be deleted, and you will not be notified.
5. Make a report
If you have a concern, you must report it electronically via our online reporting system.
6. Protection of whistleblowers
We understand that it can be difficult to report a concern. We will do our best to protect individuals who report concerns in good faith from retaliation.
7. Processing of reports
We will acknowledge receipt of a whistleblower report within seven days. We will provide prompt and appropriate feedback on the report during the investigation. We will conclude the investigation and provide a final follow-up within 90 days of submitting the report.
8. Confidentiality
We will maintain the confidentiality and security of whistleblowing reports and will only share the information on a “need to know” basis.
9. Revision of the policy
This policy will be reviewed annually to ensure that it remains relevant and effective. Read the full whistleblower policy for ABC Group here.
10. Questions
Any questions regarding the whistleblower scheme may be directed to Lene Facius by phone on +45 4026 2630 or by email: [email protected].