Whistleblowing

The purpose of whistleblowing is to make it easier to report irregularities of a serious nature. Employees should feel secure, and know that they can report irregularities and serious incidents relating to the company without the fear of negative consequences. 

A whistleblowing report can be filed by anyone who in some way represents or is active in the company in a work-related context. This means all employees, interns, job applicants, consultants and temporary staff (agency staff). Board members and shareholders can also file reports, as well as those belonging to the company’s supervisory bodies, such as auditors.

The whistleblowing service is used to raise the alarm regarding the serious risk of irregularities that may affect people, our organization, the community or the environment. Cases reported may contain information about crimes, irregularities and transgressions, or other actions that are in breach of EU or national legislation in a work-related context. These include:

• Corruption and financial irregularities, such as bribes, unfair competition, money laundering, fraud and conflicts of interest.
• Crime relating to health and safety, such as the work environment, serious discrimination and harassment which is against the law.
• Environmental offenses, such as illegal handling of hazardous waste.
• Breaches of privacy, such as the erroneous use of personal data. 

As a Whistleblower, you are not obliged to have evidence to support your suspicions, however, you must have due cause to believe the information you are providing is true. As a rule you should have first-hand information, as reports only filed on the basis of rumors or hearsay are not covered by the protection. Accusations may not be made with malicious intent, or in the knowledge that the accusation is false. False or malicious accusations represent a serious breach of the employment contract, and there is no protection against retaliation in the event of false or malicious filings.  

Those filing reports do not run the risk of being of being affected by consequences thereof – either at the time of reporting or later.

We ask employees to raise issues such as discontent at the workplace or complaints relating to personal circumstances with their line manager, senior manager or HR, as such questions cannot be treated within the scope of the whistleblower function. 

If you are uncertain whether the issue you wish to raise falls within the scope of this policy, we advise you to speak to your line manager or HR. 

In the first instance, as an employee, you should report issues directly to your manager, senior manager or HR, which you can do by e-mail, telephone or in person. If you do not feel as if you can report to any of these people, you can use our web-based whistleblower function, where you can file a report anonymously by refraining from stating contact details. You can file this report using the link below. We use an external provider for the web-based whistleblower function (HaileyHR). All messages sent are encrypted, and it is not possible to trace the sender if no contact details are provided when reporting.

When filing a report, the following questions must be answered:

• Who was involved?
• When? How? Where?
• Other relevant information.
• Your name and contact details (not mandatory).

In the first instance, you should always file a report using our internal whistleblower function as outlined above. If you do not get a response, or feel the case has not been handled correctly, it is also possible to file a report via external reporting channels. The report is then filed to the competent authority, such as the Swedish Tax Agency or Swedish Work Environment Authority. 

All reports filed under the terms of this Whistleblowing policy are taken seriously, and handled both professionally and confidentially.

Only those with the authority to handle whistleblower-related cases have access to the reports that come in via the whistleblower function. The company’s HR Manager and Chief Executive Officer form part of this limited group. If reporting takes place in any other way, in line with the heading "How do you file a report?", the case is forwarded to the HR manager or Chief Financial Officer.

If a report involves any of those mentioned above, an alternative group will be set up in which the person in question is not included.

Confirmation must be provided to the whistleblower in line existing legal requirements.

• The whistleblower must be notified that the case has been received within seven (7) days.
• A conclusion is communicated to the whistleblower regarding the case within three (3) months.

In order for confirmation to be given and dialog to take place, an e-mail address must be provided. Your e-mail address will at no time be provided, and your anonymity will not be affected by providing your e-mail address. The purpose is solely to notify you that Monitor has responded to your case.

Those responsible for the whistleblower function – the HR Manager and Chief Financial Officer – will decide if the case is approved or rejected. Cases will be rejected due to the reasons below:

• The behavior in question is not reportable under this policy. 
• The case is malicious or has not been raised in good faith.
• The case has already been resolved.

If the report is approved, suitable investigation measures will be taken.

The Swedish Act (2021:980) on the protection of persons reporting wrongdoing (Whistleblowing Act) applies in a work-related context to information reported regarding maladministration for which disclosure is in the public interest, or actions that are in breach of EU or domestic legislation.

• Click here to read more about the Swedish Whistleblowing Act.

In the event of an investigation, the whistleblower must be prepared to answer any follow-up questions arising, which means full anonymity cannot be guaranteed in relation to the whistleblower unit. If you wish to guarantee full anonymity you are entitled to refrain from providing your contact details via the external reporting tool for whistleblowing. 

When a case is completed, no later than after two years (under the terms of GDPR and the Swedish Whistleblowing Act), all personal details in the case will be deleted.