Whistleblowing

Whistleblowing

• Whistleblowing means that a natural person within or outside the organization who, in a work-related context with the Alfa Group, reports/raises concerns that some form of serious wrongdoing is occurring, will occur or has occurred in the operations that is of public interest.
• The term “wrongdoing” is defined as all types of failures or improprieties, regardless of whether this is a matter of deliberate conduct or negligence. Even various types of failures or improprieties that have not yet occurred, but that are highly likely to occur, may constitute wrongdoing. Attempts to conceal any wrongdoing may, in themselves, constitute wrongdoing. Wrongdoing does not necessarily have to be recent or ongoing.
• In order to be of public interest, the circumstances must be serious, concern a group that can be described as the general public and there must be a legitimate interest in the wrongdoing being reported.
• The nature of the wrongdoing must also be such that, when making a report, the whistleblower had reasonable grounds to assume that the information about the wrongdoing was true.

Reports can be made anonymously using our internal reporting channels:

• Alfa in Sweden: Whistle (whistleportal.eu)
 https://nordicwhistle.whistleportal.eu/WhistleBlower/Form/465-802-0a8ea894800340ee920cf048714707bb

• Alfa in Denmark: Whistle (whistleportal.eu) https://nordicwhistle.whistleportal.eu/WhistleBlower/Form/465-803-7626adccaf854230b2fa6bf6ae387262

• Alfa in other countries: Whistle (whistleportal.eu) https://nordicwhistle.whistleportal.eu/WhistleBlower/Form/462-800-18c9b5fa69e4463d82efeb33dd9ad08c

• The links above bring the whistleblower to the Whistleblower Partners portal, where the whistleblower can choose to submit a new report or log in and view a previously reported case.
• After opening the reporting tool, the whistleblower can fill in the relevant category of wrongdoing. The whistleblower can also provide information about when the incident took place and describe what happened. Remember to provide as much detail as possible. The whistleblower can state their name and contact information if they wish to, but a report can also be submitted completely anonymously. In order to facilitate any investigation, please state which company in the Alfa Group the wrongdoing involves, if using the link above for any other company than Alfa Group AB.
• All information submitted via the portal is encrypted so that it cannot be traced back to the person reporting a case. When the whistleblower has submitted their case, they will see a case number and a code on their screen. It is very important for the whistleblower to save this information in order to view the case in the portal.
• The whistleblower receives confirmation about their report within seven days from submission. An initial assessment of the information provided is carried out to identify whether or not the case can be considered a whistleblower case. The whistleblower may be asked questions in connection with receipt of this confirmation. It is important that the questions asked by the investigator are answered by the whistleblower. Save your code so that you can log in and view the status of the case and answer any questions.
• Please note that the whistleblower may not share confidential documents when reporting a case and may not disclose any more confidential information than is necessary when submitting a report. Furthermore, the whistleblower may not commit a criminal offence in order to obtain the information referred to in the report. 

Whistleblowing may result in the following action:

• Investigation by management, the Board, Internal Audit or HR as a disciplinary matter
• Referral to the Police or the authorities
• Investigation by independent auditors
• Subject to an independent investigation
• Cases that are not considered to be whistleblowing are reviewed but will not be handled in accordance with the regulations of the Swedish Act on the Protection of Persons Reporting Irregularities (Whistleblowing Act). These cases will instead be handled following other internal procedures. If the case is clearly not considered to be whistleblowing, the person reporting the case (the whistleblower) will receive confirmation of this by the relevant person/unit providing feedback in the portal. In all other cases, the Alfa Group will take the action deemed appropriate, which may involve a more in-depth investigation. Suspicions of crime may be reported to the police authority. The whistleblower receives information in the portal about the action planned to be taken and/or that has been taken not later than three months after confirmation of the case has been provided.

Protection

A person who reports improprieties will be protected if this whistleblower provides such information in good faith, with honest intentions and assumes that the primary content of the information is true. If it later proves to be the case, for example, after an investigation, that the information was incorrect, this will be accepted provided that the person acted in good faith. The whistleblower will not be subject to any reprisals (termination of employment, transfer, dismissal, ostracizing, harassment or salary reduction as punishment) or disciplinary action from the Alfa Group as a result of having reported wrongdoing. Any evidence that can be traced back to the whistleblower will be kept confidential as far as possible. The Alfa Group does not tolerate a person who has reported a case of improprieties being subjected to negative treatment, discrimination or other form of reprisals. Reporting of false, malicious or baseless accusations mean that the whistleblower will not have such protection, and such reporting could result in disciplinary consequences under labor law. If the whistleblower themselves are involved in the improprieties, the whistleblower will not be protected from disciplinary or legal action after having submitted a report.

Processing of personal data

All data is transferred and stored securely though encryption and the use of password protection. The General Data Protection Regulation (GDPR) applies to the processing of personal data. The Swedish Act on the Protection of Persons Reporting Irregularities (2021:890) contains additional regulations to the GDPR on follow-up of whistleblowing cases. The Alfa Group has an obligation to document verbal reports that are submitted via the channel if the whistleblower consents to this. The whistleblower shall be given the opportunity to check, correct and approve the record by providing a signature. The processing of personal data that takes place as part of a reporting and follow-up case must be necessary for remedying the wrongdoing that has been revealed in a report or that appears in a follow-up case. The Alfa Group has an obligation to retain written reports and documentation on verbal reports as long as necessary. Personal data may be processed to take necessary action in a case, to use reports as evidence in legal proceedings and/or to comply with laws or regulations. Personal data that are obviously not relevant to processing a certain report may not be collected and are to be erased as soon as possible if they have been erroneously collected. Personal data that are collected and do not concern a whistleblowing case may be processed as long as this takes place in accordance with the GDPR. Data are to be deleted within two years after the follow-up case has been closed.