Whistleblowing
Introduction
HGF has decided to pursue the highest possible level of ambition regarding openness, honesty, and accountability. In line with this decision, we expect employees and others we work with who have serious concerns about any part of HGF's operations to make their voices heard and report them.
Employees are often the first to discover suspected irregularities and misconduct within an organization. In accordance with HGF's Code of Conduct and HGF's Work Environment Procedures, employees shall report all suspicions of irregularities and misconduct to their immediate supervisor or manager. If the employee has reservations about this or fears harassment or other retaliation, the Whistleblower system serves as an alternative way to report.
The purpose of this Whistleblower Policy is to offer employees an alternative channel for reporting suspected irregularities and misconduct without risking subsequent retaliation, discrimination, or other penalties. The whistleblower system is intended for serious misconduct and as a supplement to standard reporting procedures.
This policy applies to all employees at HGF or its subsidiaries. The policy also represents a commitment from the company that it will promptly handle and thoroughly investigate incoming reports of misconduct by HGF or its employees, consultants, contractors, or suppliers, and take adequate action.
The whistleblower system gives all employees an opportunity to act responsibly to preserve HGF's reputation and the public's trust in HGF's operations. The purpose of the policy is to ensure that suspicions of irregularities and misconduct are handled and addressed correctly.
What is whistleblowing?
Whistleblowing is an alternative way to report irregularities and misconduct to bring serious suspicions of irregularities and misconduct to the attention of the company's management.
What does the whistleblower policy cover?
The policy covers serious irregularities that could have a detrimental impact on the company's business operations and that, due to the nature of the irregularity, cannot be reported through normal channels, such as:
- illegal activities;
- financial fraud (e.g., improper accounting, violations of internal control procedures, asset misappropriation, or embezzlement);
- bribery and corruption (e.g. conflicts of interest, bribery, sponsorship and donations, gifts);
- violation of competition law (e.g., price fixing, exchange of price-sensitive information, collusion on bids with competitors);
- serious threats to the environment, health, and safety;
- activities that, in ways other than through law, treaty, or agreement, are to be considered seriously inappropriate conduct (e.g., discriminatory employment practices, the use of child labor, human rights violations).
What is not covered by the whistleblower system
- Alcohol or drug problems
- Petty theft at work
- Less serious workplace problems
- Crimes committed by persons not in key or leading positions within the Group
These and other minor irregularities should be reported through the usual channels to your immediate superior.
Who is protected?
The company will ensure that incoming reports and suspicions of irregularities are handled correctly and discreetly. Any employee who makes a disclosure or expresses a suspicion under this policy will be protected if the employee:
- discloses the information in good faith;
- believe it to be substantially correct;
- not acting maliciously or making false accusations; and
- does not pursue personal or financial gain.
The company will take measures to minimize any potential difficulties that may arise as a result of a person reporting suspected misconduct. If required to testify in a criminal or disciplinary case, the company will ensure that they receive legal advice regarding this.
Where do you leave a tip?
Anyone who has a complaint or concern about impropriety in the company's operations should first contact their supervisor, manager, or the person in charge of the relevant department. Depending on the nature of the impropriety and the person suspected of misconduct, the supervisor or manager will decide whether the matter should be escalated to the Company's management.
On the other hand, and as a supplement to the usual reporting channels and procedures for handling serious misconduct, you can submit a complaint or tip to:
The company's chairman of the board.
Jan Johansson
[email protected]
+46 705 92 0605
The company's legal representative
Carl-Johan Krusell
[email protected]
+46 70 989 65 02
How will the information be handled?
Jan or Carl-Johan will, after the reception, decide whether the incoming information is of a nature that it should be handled within the Whistleblower system. If the information is not of such a nature that it can be handled within the framework of the system, the message will be deleted. To protect the individuals involved and those suspected of misconduct, an initial investigation will be carried out to determine whether a more comprehensive investigation should be conducted. If urgent measures are required, these may be implemented before an investigation is carried out. All handling and storage of personal information will take place at the company's head office in Halmstad, Sweden.
Privacy and anonymity
Regarding every whistleblower report, the company will, to the greatest extent possible, respect the reporter's wishes for confidentiality. However, it may be difficult to follow up on and verify anonymous reports if the reporter is unwilling to disclose their name.
False and malicious accusations
The company's objective is to maintain the highest possible honesty and reliability in its business operations. The company assures that sufficient resources will be allocated to investigate every report received. However, it is important that those considering a report ensure it is well-founded. No accusations may be made maliciously or with knowledge that they are false. The company will consider any intentional submission of false or malicious reports by an employee as a serious disciplinary offense.
The right to information
Once information ("Data") has been collected, the person or persons involved ("Data Subject(s)") will be informed. If it is not possible to provide the Data immediately, for example, because it would jeopardize an ongoing investigation, the company will provide the Data to the Data Subject(s) only when such a risk no longer exists. However, the Data Subject(s) shall be informed as soon as possible, and in any event no later than when Data concerning the Data Subject(s) is used. Information must also be provided to any person who requests it, stating whether or not Data has been registered about them. As a general rule, such information shall be provided within one month and never later than four months after the request is made. The information provided upon request may not reveal the identity of the person who provided the information.