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Whistle-blower

Do you have something on your mind?
We are here to listen!

We uphold a healthy and open culture, where each employee has a responsibility to comply with current regulations and act ethically. We can solve many situations by talking to each other straight after they occur. Sometimes things can happen that require a completely different approach.

Regardless, it is important for us that problems or more serious issues are revealed so that we, as an organisation, can act. In more serious cases such as forms of misconduct, or where there is a danger to life and limb, it is important that these come to light early on.

As an employee or partner, you are a key factor in this process. If you have a feeling that something is not as it should be, it is important for us that you can highlight this in a safe manner. This is why we offer you two different options to have your say, through our internal reporting system or whistleblowing using an external independent operator.

What can you report?

If you feel you need to raise an issue, this is reason enough to report it. It is important for us as an organisation to live up to our values. We therefore need help discovering when these are not complied with so that we can clearly show where to draw the line and what values ​​are at stake.

An example of a problem you can report is when an individual in our organisation or a partner company violates our code of conduct, which defines what we as a company stand for, our values ​​and how we do business. Other likely issues can be more serious misconduct and offences such as fraud, embezzlement, corruption, breaches of trust, information theft, corporate espionage and data breaches.

If our guidelines are not helpful, you can use the following questions to decide on what steps to take.

• Is there an issue that you think violates what we stand for and how we describe how we should carry out our work duties?
• Do you consider what has happened to be justifiable from a legal or ethical perspective?
• Would our business come into disrepute if the situation became known to the general public?
• How would you view the issue if you were a customer or another stakeholder?

1. Internal reporting

As soon as you experience misconduct or something irregular, you should contact either your line manager or their manager. If you feel that you cannot trust any of these, for example if you suspect that they are involved, you should first raise the issue with management.

Do you feel in doubt about raising the issue with a manager? Then you should use the whistleblowing system.

2. Whistleblowing

Sometimes, it may not be appropriate to raise an issue through internal reporting processes because of what has to be reported. For this reason, we provide access to a whistleblowing system. This is an important safety valve for both us and our employees. That is why we use an external independent operator, Whitepaper Advisors. Through their Trumpet whistleblowing system, you can anonymously and confidentially report serious misconduct committed by management or other key individuals in the company. Refer to our whistleblowing policy.

What can be reported?

According to Swedish law, there are restrictions on what may be handled in a whistleblowing system. Therefore, using the whistleblowing system, you may not report issues that do not constitute serious misconduct, such as general dissatisfaction with how the company is run, with management, salaries or other staff issues. Incidents committed by individuals who are not part of management or who are not key persons in the company may not be dealt with in the whistleblowing system either.

Reports submitted through the Trumpet whistleblowing system must be based on concrete suspicions. Proof against the suspect is not required, but accusations cannot be made maliciously or with the knowledge that the accusations are false. False or malicious accusations are a serious breach of the employment contract. Read more in our whistleblowing policy.

Who can submit a report?

Anyone who represents our organisation in any way can submit a report in the whistleblowing system. This includes board members, all employees (permanent employees, probationary employees, fixed-term employees, full-time and part-time employees), trainees and hired staff (agent staff). Customers, suppliers, consultants and partner employees are also given access to the system.

How case management works

Trumpet is an external whistleblowing service that provides a secure process where you, as a whistleblower, can be completely anonymous. If you do not include your name in the report yourself, it is not possible to see who submitted the case in the system. Trumpet has been developed based on the highest standards of confidentiality and security.

Trumpet complies with the EU’s GDPR directive and the EU directive protecting whistleblowers, as well as Swedish legislation regarding special protection against reprisals for employees who blow the whistle on serious misconduct.

The system is the brainchild of Whitepaper Advisors, a company with solid experience of investigating and helping organisations deal with misconduct. Browse to www.trumpet-whistleblowing.eu for more information.

Process, step by step:

  1. 1. Complete anonymity is guaranteed when reporting in Trumpet. Whistleblowers are not disclosed unless they wish to make themselves known.

2. When you report an event in the system, an encrypted case is created in the whistleblowing system for which you receive a unique encryption key.

3. An external independent case manager at Whitepaper Advisors always processes your case and makes a first assessment of your report. Only you and your case manager can access your case using your own encryption key.

4. The process can be speeded up if you actively make the choice to disclose your identity to the independent case manager. In so doing, you and your case manager administrator can have an effective and secure dialogue — no one else will find out who you are. (It is also possible for you to choose to disclose your identity to the organisation.)

5. A recommendation is submitted to our organisation’s whistleblowing committee once your case manager has made an assessment. This committee, in turn, decides how the case is to be taken forward and what measures are to be taken. If your report concerns anyone in our committee, they will be excluded by Whitepaper Advisors before the recommendation and report are submitted. Those involved in the committee are outlined in our whistleblowing policy.

6. Whitepaper Advisors’ case manager notifies you of the current case status and the committee’s decisions through a secure Trumper login.

How to report

Your report is submitted to Trumpet using a web link, by phone or by post. Reports can be submitted 24/7 both in Swedish and English. A report in Trumpet is always handled with anonymity maintained and with the utmost confidentiality. If you want to ensure your activity is not tracked, you should choose a private computer or mobile phone and access the service from a network you trust, for example your home network.

• Submit a report via the Trump website by browsing to
www.trumpet-whistleblowing.eu on any device (computer, tablet or mobile phone) and then entering our organisation code below to login to the whistleblowing page.

• Reporting by phone or post means a process that is somewhat different from the online channel. Read more on Trump’s website about what applies for each reporting option.

Trumpet whistleblowing:
www.trumpet-whistleblowing.eu

Use our organisation code:
MIHWB

Trump’s website provides clear guidelines about the entire process. It has a FAQ section describing each step.

Whistleblowing reporting

Trumpet whistleblowing:
www.trumpet-whistleblowing.eu

Use our organisation code:
MIHWB