Varslerpolicy

At SSG Standard Solutions Group AB, we strive to have an open and transparent workplace where misconduct should not occur.

If you suspect that misconduct is ongoing or past misconduct, it should be easy and safe to speak up. That's why we have clear and secure ways to report suspected misconduct. By making it easy to report, we work together to promote the trust that our employees, customers, and the public have in us.

Definitions

• GDPR: General Data Protection Regulation ((EU) 2016/679), which is a European regulation governing the processing of personal data and the free movement of such data within the European Union. 
• Whistleblower Directive: Directive 2019/1936 on the protection of persons who report breaches of Union law.
• Whistleblower Act: Act (2021:890) on the protection of persons who report wrongdoing. 
• Misconduct: Actions or neglections that have come to light in a work-related context and which are in the public interest to disclose.
• Reporting: Verbal or written disclosure of information about wrongdoing. 
• Internal reporting: Verbal or written disclosure of information about wrongdoing within a private sector company.
• External reporting: Verbal or written disclosure of information about wrongdoing to the competent authority or authorities.
• Disclosure or public disclosure: Making information about wrongdoing available to the public.
• Reporting person: A person who reports or discloses information about wrongdoing acquired in connection with their work-related activities.
• Retaliation: Any direct or indirect action or neglect that occurs in a work-related context and is prompted by internal or external reporting or disclosure, and which causes or may cause unjustified harm to the reporting person.
• Follow-up: Any action taken by the recipient of a report to assess the accuracy of the allegations made in the report and, where appropriate, to address the reported violation, including through measures such as internal investigations, inquiries, prosecution, recovery of funds and discontinuation of proceedings.
• Feedback: Providing reporting persons (‘whistleblowers’) with information on the actions planned or taken as a follow-up and on the reasons for such follow-up.

1.  Who can blow the whistle?

You are eligible for protection under the Whistleblower Act if you are an employee, volunteer, intern or active shareholder. This also applies to individuals who work with us in other capacities, such as contractors, subcontractors or suppliers, as well as those who are part of our governance structure. Contractors, subcontractors and suppliers to us who have become aware of misconduct within the organisation may also report them. You can also report misconduct if your work-related relationship with us has ended or has not yet begun.

2. What can I blow the whistle on?

If you suspect a possible misconduct, breach of law and/or rules, we encourage you to report this to us as a whistleblowing case. When reporting, it is important that you had reasonable grounds to believe that the information about the misconduct reported was true at the time of reporting. When assessing whether reasonable grounds existed, the circumstances and information available to you at the time of reporting should form the basis for determining whether you could have assumed that the misconduct was true. The above requirements must be met in order for you to receive protection under the Whistleblower Act.

2.1 Abuses of public interest

You can report information about abuses that have come to light in a work-related context and which are in the public interest to disclose. For other types of personal complaints that are not in the public interest, for example disputes or complaints about the workplace or working environment, we encourage you to contact your responsible person, HR or other appropriate responsible person. This is to ensure that these cases are handled in the best possible way.

2.2 Irregularities that contravene EU law 

It is also possible to report information about misconduct that have come to light in a work-related context and that contravene EU legal acts or provisions. If you suspect that this is occurring, please read Section 2 of the Whistleblower Act and the scope of application of the Whistleblower Directive in Article 2 and Annex 1 for applicable laws.

3. How do I report?

3.1 Written reporting

You can report your case anonymously through our digital service Hailey HR.

Please describe what happened in as much detail as possible, so that we can ensure that appropriate measures can be taken.

3.1.1 Sensitive personal data

Avoid including sensitive personal data about individuals mentioned in your report unless it is necessary to describe your case. Sensitive personal data includes information about ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, a person's sex life or sexual orientation, genetic data, and biometric data used to uniquely identify a person.

3.1.2 Anonymity

You can remain anonymous throughout the process without affecting your legal protection, but you also have the option of revealing your identity under strict confidentiality. In some cases, anonymity may make it more difficult to follow up on the case and take the necessary measures, but in such cases we may ask you to reveal your identity later under strict confidentiality.

3.1.3 Follow-up & login

When a report is submitted, SSG case managers receive an email with information about the report. As a whistleblower, you will also receive an email with information about what happens next – provided that you have specified an email address.

As a whistleblower, you will receive feedback in two weeks as to whether the case qualifies as whistleblowing or not. If the case qualifies as whistleblowing, you as the reporter will also receive feedback on possible action.

4. What are my rights?

4.1 Right to confidentiality

During the handling of the case, we will ensure that your identity as the reporting person is treated confidentially and that unauthorised personnel are prevented from accessing the case. We will not disclose your identity without your consent, unless required to do so by law and we will ensure that you are not subjected to reprisals.

4.2 Protection against reprisals

Whistleblowing provides protection against negative consequences of reporting misconduct in the form of a prohibition against reprisals. Protection against reprisals also applies, in relevant cases, to persons in the workplace who assist the reporting person, your colleagues and relatives in the workplace, and legal entities that you own, work for or are otherwise associated with.

This means that threats of reprisals and attempts at reprisals are not permitted. Examples of such reprisals include being dismissed, having your duties changed, being subjected to disciplinary measures, being threatened, discriminated against, blacklisted within your industry, or similar, because you have blown the whistle.

Even if you are identified and subjected to reprisals, you are still covered by the protection if you had reasonable grounds to believe that the reported misconduct was true and fell within the scope of the whistleblower law. Please note, that protection is not granted if it is a crime to obtain or have access to the information reported.

Protection against retaliation also applies in legal proceedings, including those relating to defamation, copyright infringement, breach of confidentiality, violation of data protection rules, disclosure of trade secrets, or claims for compensation based on private law, public law or collective labour law, and you shall not be held liable in any way as a result of reports or disclosures, provided that you had reasonable grounds to believe that it was necessary to report or disclose such information in order to reveal an irregularity.

4.3 Disclosure of information

The protection also applies to the disclosure of information. This presupposes that you have reported internally within the company and externally to an authority, or directly externally, and no appropriate action has been taken within three months (six months in justified cases). Protection is also provided if you have reasonable grounds to believe that there may be a clear danger to the public interest if the information is not disclosed, for example in an emergency. The same applies if there is a risk of reprisals in the event of external reporting, or if it is unlikely that the misconduct will be remedied effectively, for example if there is a risk that evidence may be concealed or destroyed.  

Please note, that this protection does not apply if you, as the reporting person, disclose information directly to the media in accordance with an otherwise applicable protection system for freedom of expression and information. You therefore still have whistleblower protection and freedom of acquisition where applicable.

4.4 Right to review documentation during meetings with coordinator

If you have requested a meeting with case handlers, they will, with your consent, ensure that complete and accurate documentation of the meeting is preserved in a durable and accessible form. This is done by documentation the meeting. Afterwards, you will have the opportunity to check, correct and approve the documentation by signing them.

5. GDPR and handling of personal data

We always do our best to protect you and your personal data. We therefore ensure that our handling of such data is always in accordance with the General Data Protection Regulation (GDPR).

In addition, all personal data that is not relevant to the case will be deleted, and the case will only be saved for as long as it is necessary and proportionate. At most, a case may be processed for two years after its conclusion. For more information about our handling of personal data, see the Company's personal data policy.

6. Further contact

If you have any further questions regarding how we handle whistleblower cases, you are always welcome to contact the coordinator.

6.1 Contact details for coordinator

Name: Sofia Tunmats

Position: Head of HR

Email: sofia.tunmats@ssgsolutions.com 

Phone: +46 709 49 25 13

 

Name: Ida Karlsson

Position: Advisor, Work Environment

Email: ida.karlsson@ssgsolutions.com   

Phone: +46 726 01 22 41

 

The above internal contact person(s) may take over the case from the coordinator, regardless of whether the case is deemed to be whistleblowing or, for example, a personnel matter.