1. BACKGROUND
DISTRIKTFEM is a part of Kulturarenor. This Whistleblower policy is mutual for all companies within Kulturarenor. Kulturarenor strives to have an open business climate, high business ethics and for the well-being of our employees. Our employees, customers and suppliers are our most important sources of insight into any deficiencies that need to be corrected. As Kulturarenor is a value-driven business, we want anyone who suspects an irregularity, which conflicts with Kulturarenor's values, business ethics or current legislation, to have the opportunity to speak up without fear of reprisals. You can choose to submit your information anonymously. To protect whistleblowers, Kulturarenor has a whistleblower policy with an associated reporting function.
2. WHISTLE BLOW MEANING
Whistleblowing means bringing potentially illegal and/or unethical activity, also known as impropriety, to management's attention.
3. WHAT CAN BE REPORTED?
Via this function, suspicions of serious irregularities can be reported. Serious irregularities include, among other things:
• Financial crime such as bribery, theft, fraud and forgery, accounting crimes and other violations of accounting and tax laws
• A conflict of interest between an employee and a company that is part of Kulturarenor
• Other serious irregularities that concern the vital interests of Kulturarenor or the lives and health of individuals, such as serious environmental crimes, major deficiencies in workplace safety and serious forms of discrimination and harassment.
4. WHO CAN APPLY?
The reporting routine can be used by all employees (regardless of employment) within Kulturarenor. Even suppliers, former employees etc. can use the function.
5. HOW ARE OTHER CASES REPORTED?
Other types of cases such as disputes, errors, complaints, minor crimes, dissatisfaction with pay and the like do not constitute whistleblower cases and should not be reported via this system. These cases must first be reported to the immediate manager or another member of the diversion group.
6. REPORTING
To ensure your anonymity, a reporting tool is provided by an external and independent actor. The reporting channel is encrypted and password protected. You never have to provide your identity if you don't want to. You can choose to report as follows: Reporting tool: Physical meeting: Please call in or alternatively notify via the reporting tool and state that you wish to meet in person
• You do not need to have proof of your suspicion but no accusation must be made maliciously or with knowledge that the accusation is false
• It is important that you describe all the facts of the case, including the circumstances that you think are less important
• Please develop your claim carefully and attach anything that may be relevant.
7. WHO ACCEPTS APPLICATIONS?
To ensure independence and confidentiality, all notifications are received by an external party who forwards the case to the Personnel Department ("Case Manager"). If a case concerns the Case Manager, the notification is sent to the Appointed Management Representative instead. If external expertise is needed, investigations can also be carried out by an external party with extensive experience of whistleblower cases and related investigations. No information about you as a notifier will be disclosed unless you have given your consent to this. You choose for yourself whether you want to be completely anonymous to the independent actor's investigators or whether you want to say who you are.
8. FEEDBACK
Within a week after your report via the reporting tool, you can log in again with your personal login and password to see any follow-up questions/comments from Kulturarenor You can follow up on your case via the reporting tool if you have written down the case number and the code that you receive when you complete your report . Log in regularly as the investigators may need to ask you additional questions and in some cases want to act quickly. Within three months at the latest, Kulturarenor will report back on the status of the matter.
9. PERSONAL DATA AND ANONYMITY
Kulturarenor take great account of the protection of personal integrity. The rights of persons appearing in cases in the whistleblower process are protected according to current data protection laws. Personal data included in case management and investigation documentation will be deleted after the investigation is completed, with the exception of cases where applicable laws state that personal data must be saved. Otherwise refer to Kulturarenor's personal data & privacy policy.
10. ABUSE
Kulturarenor will investigate all cases that are reported. It is important that any individual who raises the alarm genuinely suspects that serious misconduct is at hand. Kulturarenor take deliberately false or malicious allegations seriously and may take disciplinary action against anyone who maliciously accuses someone else.
11. RESPONSIBILITY
Kulturarenor is responsible for this policy. The policy is revised annually.