Whistleblowing

Polarn O. Pyret is committed to detect and prevent all kinds of irregularities that may seriously harm our business or employees. It is therefore important that such information is noted and investigated as early as possible. We have therefore implemented an internal whistleblower function as a complement to our normal internal reporting routines to allow for an anonymous reporting channel of suspected irregularities.

This information may be reviewed and amended by Polarn O. Pyret at any time.

 

What the whistleblower function is

Through the whistleblower function, reporting persons (e.g. employees) can report suspicious misconduct that has taken place in a work-related context and constitutes information that is of public interest that it is brought forward and acted upon or when the misconduct constitutes a violation of certain EU-law.

The whistleblower function is administered by PwC and PwC’s whistleblowing team is the first recipient of all the reports.

 

When to use the whistleblowing function

The function can be used if you suspect incidences of fraudulent conduct, corruption or other suspected malpractices. This can include incidents such as bribery, fraud, theft or other situations where someone gets a private gain or benefit because of his or her position or that a related party benefits in some way. Criminal violations, more serious misconduct and deviations from internal rules and guidelines that fall within the area of ​​irregularity must also be reported.

It should be noted that the whistleblower function is a complement to our normal internal reporting routines and not a substitute. Employees can always choose to report matters internally to managers or other superiors.

 

When not to use the whistleblowing function

The function is not suitable for reporting complaints and general views on leadership, work environment, business planning etc. It is also not suitable for reporting certain HR issues linked to individuals. If you feel uncomfortable or for other reasons do not want to talk to your manager or other superiors, you can turn directly to your HR function or any union representative.

 

Who can report?

You can report and receive protection if you in a work-related context have learned of or obtained information about misconduct, and are a reporting person, i.e., an employee, job seeker, volunteer, trainee, those hired by temporary work agencies or otherwise performing work under Polarn O. Pyret’s control and management, self-employed employee, part of Polarn O. Pyrets’s administrative, management or supervisory body, or an active shareholder in Polarn O. Pyret. The fact that you have ended your work-related relationship with Polarn O. Pyret, or that it has not yet begun, is not an obstacle to reporting misconduct under this policy.

 

How to file a report

It is important to make sure the information contained in the report you submit is as concrete as possible so that it can be processed and investigated in the appropriate manner.

A report can be submitted in writing via a web-based reporting system through a template that guides the reporting person using several questions with the purpose to clarify and specify the reported information. A report can also be submitted verbally in the web-based reporting system through a voice recording functionality. The reporting person can also book a physical meeting with PwC’s team through the web-based reporting system.

The reporting person can choose whether to disclose its identity or remain anonymous, and to report in local language. 

All reporting is made through this link:  

https://whistleblowersoftware.com/secure/966e4017-cb3d-4d8c-bceb-abd1bf6597ab

Please do not include sensitive personal information (or any personal data irrelevant for the case) about people mentioned in your report if it is not necessary to describe your case. Sensitive personal data is information about; ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, a person's sex life or sexual orientation, genetic data, and biometric data used to uniquely identify a person.

PwC will retain written reports and documentation of oral whistleblowing reporting as long as necessary, but no longer than two years after the follow-up case has been closed.

 

How reports are managed

Polarn O. Pyret has appointed designated persons (“Case Handlers”) to manage incoming reports in the internal whistleblowing function.

When a report has been received in the whistleblower function PwC’s whistleblowing team receives it and conducts an initial assessment. The report is then forwarded to Polarn O. Pyret’s Case Handlers who then decide how the case should be managed, for instance if it should be dismissed, if an internal investigation should be initiated or if there is a need for an investigation to be conducted by an external party.

Through the web-based system, PwC’s Whistleblowing team the Case Handlers communicate with the reporting person and provide confirmation in the system within seven days that the report has been received. Further feedback regarding the reported case, for instance if it is dismissed due to it not constituting a whistleblowing report or measures that have been taken such as the initiation of an investigation, will also be communicated to the reporting person through the web-based system within three months. The confirmation will be provided regardless of whether the reporting person has reported via the web form, by voice recording or at a physical meeting. 
A reporting person can follow-up a previously reported case via a unique login credential which is provided to the reported person in the whistleblower function when a case is reported. The login credentials enable the reporting person to communicate in the internal whistleblower function with PwC’s whistleblowing team and Polarn O. Pyret’s Case Handlers.

Upon receiving a report of concern, Polarn O. Pyret is responsible for conducting a thorough investigation within a reasonable timeframe. The company must also ensure that the whistleblower is protected and maintains a satisfactory work environment, taking necessary actions to prevent any form of retaliation.

Information reported through the whistleblower function is treated confidentially and in a manner which ensures a secure and effective case for those who chose to use the whistleblower function as well as individuals and third parties that may be regarded by whistleblower reports. To the extent permitted by law, and in keeping with the need to conduct a competent internal investigation, we will make every effort to maintain the confidentiality of the person reporting a whistleblowing concern. Similarly, the identity of the subject(s) of the investigation will be maintained in confidence with the same limitations.

 

External reporting channels                                                                                                                    

Irregularities can also be reported externally to supervisory or other public authorities.

An external reporting channel is a channel established by an authority for managing reporting on violations that are within the authority's area of responsibility, and which may include misconduct by any public or private entity. If you choose to report externally, you will receive the same level of protection as if you report internally. However, any follow up measures with regards to your report will in case of external reporting primarily be performed by the competent authority and not by Polarn O. Pyret or its appointed recipient.

You are always free to externally report potential violations of laws or regulations to the appropriate authorities. We then refer you to contact the relevant competent authority. An external reporting channel can, for example, be used if the reporting person does not believe that reporting to the internal whistleblowing function would be managed appropriately.

Sweden

On the following link, on the homepage of Swedish Work Environment Authority, you can find a list of external authorities for reporting certain types of whistleblowing concerns in Sweden: https://www.av.se/om-oss/visselblasarlagen/extern-rapporteringskanal/lista-over-myndigheter-med-ansvar-enligt-ansvarsomrade-enligt-forordning-2021949/

Finland

The following link on the homepage of the Finnish Chancellor of Justice introduces the process for external reporting in Finland and provides further guidance on how the reporting can be made. You can find the reporting page here: https://oikeuskansleri.fi/ilmoittajansuojelu.

Norway

On the following link, on the homepage of the The Norwegian Labour Inspection Authority, you can find a list of external authorities for reporting concerns in Norway: https://www.arbeidstilsynet.no/tema/varsling/Slik-kan-du-varsle-om-kritikkverdige-forhold/    
 

Protection against retaliation

Retaliation against any employee who reports issues of concern is strictly prohibited. This includes any negative actions, such as threats, harassment, discrimination, or adverse changes in employment conditions, taken as a result of the employee's decision to report. It is also prohibited to prevent the filing of the report.

If an employee presents information suggesting retaliation, the burden of proof lies with the employer to demonstrate that no such retaliation has occurred.

In Norway, employees are entitled to seek redress and compensation in the event of retaliation. Disputes concerning retaliation may be brought before the Norwegian Anti-Discrimination Tribunal (Nw; Likestillings- og diskrimineringnemnda), with the exception of dismissal cases.

 

Freedom of communication and freedom of procurement

In Sweden, the rights a person has under the Freedom of the Press Act (Sw. Tryckfrihetsförordningen) and the Fundamental Law on Freedom of Expression (Sw. Yttrandefrihetsgrundlagen) with regards to freedom of communication and freedom of procurement, are not limited by the Swedish Whistleblower law or this policy.

In Norway, an employee's right to freedom of expression, including the ability to voice criticisms internally within a company, is protected under Norwegian legislation. This encompasses raising issues through established whistleblowing procedures or other appropriate channels, reflecting the company's organizational structure. Such actions are underpinned by the fundamental principles of freedom of expression.

In cases where there are claims of restrictions on an individual's freedom of expression, the burden of proof lies with the party asserting such limitations. Additionally, employers are tasked with the responsibility of proving that any whistleblowing was not in accordance with these provisions.