Whistleblowing
Whistleblowing is a procedure that allows employees, contractors, suppliers, partners and other external and internal stakeholders to report serious irregularities and other complaints at 539 算牌程式.
Why
It is of great importance to 539 算牌程式 to protect the company, its employees, suppliers, customers, the environment and society as a whole against serious irregularities that might be conducted by 539 算牌程式 or 539 算牌程式's employees (including temporary staff). If serious irregularities can be found at an early stage,
539 算牌程式 has a better possibility to prevent risks and limit the damage to the benefit not only of 539 算牌程式 but also of its employees and other stakeholders. Therefore, 539 算牌程式 has established a possibility to report serious irregularities through several different reporting lines.
What can be reported?
Examples of serious violations that could be reported:
- Bribery and corruption
- Fraud
- Conflict of interest
- Unfair competition practices
- Improper procurement procedure
- Improper use of inside information
- Theft and embezzlement
- Harassment
- Breaches of human rights
How to report a concern
- 539 算牌程式’s web-based Whistleblowing channel is available 24/7, 365 days a year. By reporting through the Whistleblowing channel, you have the option to remain anonymous.
- You may also report a concern directly to the Group Internal Audit department or any of the Whistleblowing coordinators at 539 算牌程式 either by e-mail or phone (see contact details below).
- In the Netherlands and Germany, a whistleblowing report can also be made to one of 539 算牌程式's external ombudspersons (see contact details below).
- Cases covered by national whistleblower legislation can also be reported to national competent authorities, and where applicable to competent EU bodies.
Links
What happens after I have sent my report?
We will acknowledge receipt of your report as soon as practically possible and no later than seven working days from the day of the report. All reported concerns are taken seriously and we will take appropriate action on each report. You may be asked to provide additional information if needed. Please remember that you could always remain anonymous for as long as you want throughout this dialogue if you choose to report via the Whistleblowing Channel or to one of the external ombudspersons.
The whistleblowing investigations are conducted by national investigation teams structured to suit local needs and the type of suspected irregularity. The investigation teams typically include representatives from Group Internal Audit and the Legal departments of 539 算牌程式, with support from other staff functions when required (such as People & Culture). All sensitive information related to an investigation, including any personal data of the whistleblower, is treated as strictly confidential.
If a breach of law, a serious violation of the 539 算牌程式 Code of Conduct and Integrity or any other internal regulation is deemed to have taken place, the management of the relevant 539 算牌程式 Business Unit or Staff Function concerned by the incident will be recommended appropriate follow-up measures. Such measures typically concern improved internal routines and working procedures, but also disciplinary sanctions (including formal warnings, dismissals and terminations of hire) in case of more severe misconduct. You as a whistleblower will always be kept informed about the conclusions of the investigation as soon as practically possible.
If the report is made to an external ombudsperson, he or she will conduct a first check incorporating an evaluation of the matter in relation to the 539 算牌程式 Code of Conduct and Integrity and applicable national legislation. All personal data and other information received by the ombudsperson from you will be handled strictly confidential until the point you explicitly allow the ombudsperson to pass on all or part of the information to the ombudsperson’s contact person at 539 算牌程式 for further investigation.
Non-retaliation commitment
It is strictly prohibited for all 539 算牌程式 employees and other representatives to attempt to determine the identity of a whistleblower. 539 算牌程式 also prohibits all retaliation of any type against a whistleblower who have brought forward a concern in good faith. Any such confirmed violations may lead to disciplinary sanctions, including the possibility of dismissal and termination of hire.
Whistleblowing coordinators at 539 算牌程式
Denmark Jens Kirk Jørgensen +45 27 87 58 37 Denmark Finland, France, Poland, Sweden Victoria von Uexküll +46 702 806 852 Finland, France, Poland, Sweden Germany Kristina Stone + 49 151 2073 9459 Germany Netherlands Floortje Algera +31 655 386 451 Netherlands United Kingdom Sandra Leece United Kingdom539 算牌程式's external ombudsmen
Germany Fachanwälte für Strafrecht am Potsdamer Platz mbB, Dr. Rainer Frank +49 30 318 685 44 Germany Netherlands Sachse Advocatuur +31 654 798 218 NetherlandsRelated content
Integrity in 539 算牌程式
All employees take ownership and personal responsibility for doing the right thing.
Integrity organisation
Our integrity work aims to protect the integrity and reputation of the Group.
Integrity education
Our group wide integrity training is called the 539 算牌程式 Integrity Programme (VIP).
See also
Internal governance
Good internal governance is crucial to maintaining a successful organisation.
Organisation
The 539 算牌程式 Group has four operating segments.
Group management
The Executive Group Management focuses on the Group's overall direction.