Holtab’s whistleblower policy
What can be reported?
Suspicion of serious misconduct can be reported via this function. Serious misconduct includes:
- financial crime such as bribery, corruption, theft, fraud and forgery, accounting offenses and other breaches of accounting and tax legislation
- a conflict of interest between an employee and Holtab
- other serious irregularities relating to Holtab’s vital interests or individuals’ lives and health, such as serious environmental crimes, major shortcomings in workplace safety and serious forms of discrimination and harassment.
Who can file a complaint?
The reporting procedure can be used by all employees (regardless of type of employment) in all of Holtab’s companies. Also suppliers, former employees, etc. can use the function.
How are other matters reported?
Other types of cases such as disputes, errors, complaints, minor crimes, dissatisfaction with salary and the like do not constitute whistleblowing cases and must not be reported via this system. These matters must, in the first instance, be reported to the immediate manager or other member of the management team.
To ensure your anonymity, a reporting tool is provided by an external and independent operator. The reporting channel is encrypted and password protected. You never have to disclose your identity if you don't want to. You can choose to report as follows: Reporting tools: You can report anonymously via this channel. Tel: 0477–55000 Physical meeting: Please call in or notify via the reporting tool and indicate that you wish to meet in person.
- You do not need to have evidence of your suspicion, but accusations must not be made with malicious intent or with the knowledge that the accusation is false
- It is important that you describe all the facts about the matter, including the circumstances that you think are less important
- Please elaborate on your statement carefully and attach anything that may be relevant.
Your report should contain the following information
- The type of misconduct you wish to report.
- Where it happened.
- When it happened. Enter the date and time and whether it is something that has happened repeatedly.
- Any documentation available to you. If you do not have access to documentation, but you know that it exists, state what type of documentation it is and where it is located.
- Information about other measures you may have taken in connection with what has happened. Please note: It is important that you read and understand the information you find via the Privacy Information link before submitting your report. You should not submit any personal data that is of no significance to the report. However, if you submit such data, we may delete it without informing you.
Who receives the report?
All reports are received by Holtab’s HR Manager and the Quality and Environmental Manager. If external expertise is required, investigations can also be carried out by external parties with extensive experience of whistleblowing cases and related investigations. No information about you as a whistleblower will be disclosed unless you have given your consent to this. You decide whether you want to remain completely anonymous to the independent actor’s investigator or whether you want to say who you are.
Within one week of 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 Holtab. You can follow up on your case via the reporting tool if you have noted the case number and the code you received when you submitted your report. Log in regularly, as investigators may need to ask you additional questions and in some cases want to act quickly. Holtab will report back on the status of the case within three months at the latest.
Personal data and anonymity
Holtab takes the protection of personal privacy very seriously. Rights of persons who appear in cases in the whistleblowing process are protected in accordance with applicable data protection laws. Personal data included in the case management and investigation documentation will be deleted after completion of the investigation, with the exception of where applicable laws stipulate that personal data must be saved. Reference is otherwise made to Holtab’s personal data policy.
You can also make a report to the competent authority responsible for the area to which your report relates. When the new Whistleblowing Act came into force, the authorities below have established external whistleblowing channels to which they can turn with their suspicions. These authorities are: The Swedish Work Environment Authority, the Swedish National Board of Housing, Building and Planning, the Swedish National Electrical Safety Board, the Ecocrime Authority, the Swedish Real Estate Agency, the Swedish Financial Supervisory Authority, the Public Health Agency of Sweden, the Swedish Authority for Privacy Protection, the Swedish Inspectorate for Strategic Products, the Swedish Inspectorate for Healthcare and Social Care, the Swedish Chemicals Agency, the Swedish Consumer Agency, the Swedish Competition Authority, the Swedish National Food Agency, the Swedish Medical Products Agency, the County Administrative Board, the Swedish Civil Contingencies Agency, the Swedish Environmental Protection Agency, the Swedish Post and Telecom Agency, the Swedish Government Offices of Sweden, the Swedish Tax Agency, the Swedish Board of Forest Agency, the Swedish Gambling Authority, the Swedish Government’s Energy Agency, the Swedish Board of Agriculture, the Swedish Board for Accreditation and Technical Inspection, the Swedish Radiation Safety Authority and the Swedish Transport Agency.
Holtab will investigate all cases that are raised. It is important that every individual who raises the alarm really suspects that there is serious misconduct. Holtab takes a serious view of deliberately false or malicious accusations and may take disciplinary action against anyone who in bad faith accuses someone else.
CEO Patrik Persson is responsible for this policy. The policy is revised annually.