Whistleblowing

Sometimes it is not appropriate, based on what you need to tell us, to raise the issue through the usual channels in our organization. In such cases, we offer you the possibility to use a secure whistleblowing function. This is an important safety valve for us and for you as an employee. That’s why we use Trumpet, a whistleblowing tool that allows you to anonymously and confidentially report wrongdoing.

Do you have something to tell us? We want to listen!

We are committed to a healthy and open culture, where every employee has a responsibility to follow the rules and act ethically. Many situations can be resolved by talking to each other directly when they arise. Sometimes things can happen that require a completely different approach. Regardless, it is important for us that problems or more serious issues come to light so that we as an organization have the opportunity to act. In more serious cases such as various types of misconduct, or where there is a risk to health and life, it is important that it comes to the surface in good time.

In this work, you as an employee or partner are a key factor. That is why we offer you the possibility to blow the whistle to an external and independent advisor, with the possibility to remain completely anonymous. The following information describes the whistleblowing process in more detail. For a more detailed and comprehensive description, please see our Whistleblowing Policy.

What can be reported?

There are legal restrictions on what can be handled in a whistleblowing function. Therefore, through the whistleblowing function, you may only report matters that constitute misconduct that there is a public interest in bringing to light (or breaches of certain other legislation) that you have become aware of in your work with us. Our whistleblowing channel should only be used to report wrongdoing within our own organization. As a starting point, general dissatisfaction with how the business is run, leadership, pay or other personnel matters are not such grievances that should be reported through a whistleblowing function. Misconduct that there is a public interest in bringing to light is typically misconduct that affects the public at large, such as financial crime, environmental crime and misconduct that causes imminent danger to the life and health of persons.

A report via the whistleblowing function Trumpet must be based on concrete suspicions. You do not need to have proof of your suspicion, but no allegation may be made with malicious intent or with the knowledge that the allegation is false. False or malicious accusations are a serious breach of the employment contract. Nor should allegations be based solely on rumor or hearsay. Read more in our whistleblowing policy.

Who can make a notification?

A whistleblowing report can be made by anyone who in any way represents our organization or is professionally involved in it. This includes board members, shareholders working in the organization, all employees (permanent, probationary, fixed-term, full-time and part-time), consultants, trainees, volunteers and agency staff.

How case management works

Trumpet is a whistleblowing tool that provides you with a secure process where you as a whistleblower can remain completely anonymous. If you do not print your name in the report, it is not possible to see who submitted the case in the function. Trumpet is developed to the highest standards of confidentiality and security.

All cases are handled by independent external case handlers with extensive experience in assessing, investigating and helping organizations deal with different types of irregularities. More information on Trumpet can be found here. Trumpet complies with the requirements of the EU General Data Protection Regulation (GDPR) and the Swedish Whistleblowers Act (Act on the Protection of Persons Reporting Misconduct).

The process, step by step:

• By reporting in Trumpet, you can ensure that you are completely anonymous – no one will know who you are unless you choose to be open about your identity.
• When you report an incident in the feature, an encrypted case is created in the whistleblowing system to which you receive a unique encryption key.
• An external independent expert – a Trumpet whistleblowing officer – always receives your case and makes the initial assessment. Only you and your case officer can access your report using your encryption keys.
• To facilitate the process, you can actively make a choice to be open about your identity to the independent case officer – but not to our organization. This way, you and your case officer can have an effective and safe dialogue – no one else will know who you are. (There is also an option for you to also choose to be open with your identity towards our organization).
• After your case officer has made his/her assessment, a recommendation is made to our organization’s Whistleblowing Committee. If any member of the committee is concerned by your report, they will be excluded by the officer before the committee is given access to the report and the officer’s recommendations. The members of our Whistleblowing Committee are listed below. The Whistleblowing Committee decides how to proceed and what action to take. You can read how the committee works and who is on it in our whistleblowing policy.
• Case handlers communicate the status of the case and the Committee’s decision to you through the secure encrypted login on Trumpet. It is therefore important that you save the encryption key in an appropriate way.

How to report

You go to a webpage in the whistleblowing tool Trumpet and choose whether you want to report via an online form, phone or letter. Reports can be made 24 hours a day, 7 days a week. A report through Trumpet is always handled anonymously and with the utmost confidentiality. If you want to exclude the possibility of someone tracking your activity, you should choose a private computer or mobile phone and access the service from a network you trust, such as your home network.

The Trumpet system provides clear guidance throughout the process. Answers to the most frequently asked questions are provided at each step.

If you choose to submit your report by phone or letter, it is important that you provide some form of contact information so that the case officers can give you your login details to the case page in Trumpet. It is on the case page that the case officers will provide feedback on how the case is progressing. If you wish to remain anonymous even in relation to Trumpet, it is important that you carefully consider what contact details you provide.

You can also submit your notification through a face-to-face meeting. If you wish to request a face-to-face meeting, please contact Trumpet via the online form, telephone or letter. If you wish to report through a face-to-face meeting, anonymity cannot be promised and you should be aware that the person you may meet may be directly employed by us.

Start the application

You can start your report in the Trumpet whistleblowing tool by clicking on the “Start your report” button. You can also report by typing the address gekas.trumpet-whistleblowing.eu on any device (computer, tablet or mobile phone) to access the whistleblowing page.

Reporting to authorities

In addition to using our own whistleblowing channel, you have the option of submitting your report to a public authority. This is called “external reporting”. External reporting gives you the same protection as using our own whistleblowing channel and allows you to report the same type of wrongdoing as described above.

Please note that different authorities are responsible for reporting wrongdoings in different areas. For example, the Privacy Protection Authority handles reports of personal data breaches. The procedures applied and the means by which you can report may vary from one authority to another, but you will always be able to make your report orally, in writing or through a face-to-face meeting.

There are a large number of different authorities that are tasked with managing the external reporting procedures in different areas. For an exhaustive list of which authorities are responsible for which areas, as well as contact details for each authority, we refer you to the Swedish Work Environment Authority’s website.

Freedom of communication and acquisition

In Sweden there is something called freedom of information. This is part of freedom of expression and applies to all persons who provide information for the purpose of it being published and made available to the public. Freedom of communication means that the public authorities – i.e. the state, regions and municipalities – may not penalize anyone who has provided information that has been published. Note that freedom of information in itself does not prevent a private employer from acting on the information provided. Freedom of communication only applies if the information is shared with someone who is the author of books, newspapers, TV and radio programs or similar publication media. It should be emphasized that freedom of communication has limits – for example, there is no impunity if someone breaks so-called qualified confidentiality obligations through communication.

In addition to freedom of communication, there is also something called freedom of acquisition. Freedom of access means that anyone can seek out information on any subject for the purpose of publishing it or exercising their freedom of communication, without being penalized by the public authorities. However, freedom of access is limited in that information cannot be obtained through certain criminal acts, such as theft or hacking. Freedom of acquisition does not prevent private employers from acting on the acquisition of the information.