Whistleblowing

A whistleblower is someone who alerts management about potentially illegal or unethical activity within the organization.

Background

Gullers Grupp and its subsidiaries strives to always maintain a corporate culture that is open, highly ethical, and prioritizes the well-being of the employees. Our co-workers, clients, and contractors are the best sources of information on any grievances that need to be rectified. Our core values guide our organization. As such, we want to make sure that anyone who suspects unethical or illegal activity feels safe to report that to management without fear of repercussions. The whistleblower policy and anonymous reporting tool exist to serve and protect anyone who chooses to report grievances within the organization.

What do I report?

Suspicions of serious misconduct, unethical or illegal activity can be reported through our third-party reporting tool. Some examples of activity that should be reported:

– financial misconduct, including bribery, corruption, theft, fraud or forgery, and other activities that are illegal according to current accounting and tax laws

– a conflict of interest between an employee and the company or its subsidiaries

– other incidents that involve the company, or the health and safety of individuals, for example breaches of environmental law, workplace safety, or serious cases of discrimination and/or harassment.

Where can I report other incidents?

The whistleblower policy does not apply to minor incidents, including internal disputes, minor grievances, complaints, misdemeanors, salary negotiations etcetera. These incidents are reported to the managing director or other appropriate member of management.

Reporting

In order to maintain complete confidentiality and anonymity, the reporting tool is provided by a third party. The communication channel for reporting incidents is both encrypted and password-protected. You are not required to submit any personal information. However, doing so might help provide a starting-point for any internal investigations. The reporting tool can facilitate a text-based report, a voice recording, or a request for an in-person meeting. 

Report via the tool by clicking on this link.

– You do not need to provide proof. However, making an accusation with the intention to hurt someone else, or that is deliberately false, is strictly forbidden

– It is important that you describe everything you know about the incident, including any facts you might deem less important

– Describe your claim in detail, and make sure to attach any documents, photos, or other material that might be relevant.

Who will receive my report?

All reports are handled by a third party. It is up to you whether you want to share personal information or remain anonymous when interacting with the third-party investigators. Personal information will never be shared without your explicit consent. Should you choose to provide personal contact information, it could help provide a starting-point for any internal investigations. 

Feedback

You will receive a confirmation notice within one week of submitting your report. You can re-enter the reporting tool using your personal log in and password to review any follow-up questions and comments. To see detailed information about your incident report, you need to input the incident number provided to you at the time of submission. Make sure to check back regularly, as investigators could have further questions and may want to act quickly. Within three months of submitting your report, you will receive a complete account of the incident and any investigations.

Data privacy

We respect your personal privacy. Individuals that are part of whistleblower reporting are covered by applicable data privacy laws. Personal data in the incident report and investigation documentation will be deleted upon the conclusion of the incident, not including situations where law dictates data must be saved. For other matters, see our privacy policy.  

Abuse of service

We will investigate all incidents that are reported. In this case, concrete suspicions must be established before reporting. Any reporting that is done to intentionally hurt someone, or that is deliberately false, will be regarded as a very serious offence and might result in disciplinary measures taken against that individual.

External whistleblower reporting

Incidents can also be reported externally to the appropriate government agency for feedback and further investigation, or to an EU institution or governmental body, if applicable. More information can be found at: https://www.av.se/en/about-us/contact-us/

How can I submit a whistleblower incident report to the appropriate government agency?

You can also submit an incident report to the appropriate government agency. The following agencies have established channels for whistleblower reporting, in accordance with the new whistleblower law: The Swedish Work Environment Authority, Swedish National Board of Housing, Building and Planning, National Electricity Safety Board, Swedish Economic Crime Authority, Swedish Estate Agents Inspectorate, Swedish Financial Supervisory Authority, Public Health Agency of Sweden, Swedish Agency for Marine and Water Management, Swedish Authority for Privacy Protection, Inspectorate of Strategic Products, Health and Social Care Inspectorate, Swedish Chemicals Agency, Swedish Consumer Agency, Swedish Competition Authority, Swedish Food Agency, Swedish Medical Products Agency, County Administrative Boards, Swedish Civil Contingencies Agency, Swedish Environmental Protection Agency, Swedish Post and Telecom Authority, Government Offices, Swedish Inspectorate of Auditors, Swedish Tax Agency, Swedish Forest Agency, Swedish Gambling Authority, Swedish Energy Agency, Swedish Board of Agriculture, Swedish Board for Accreditation and Conformity Assessment, Swedish Radiation Safety Authority and the Swedish Transport Agency.

Accountability

The managing director and/or other members of management are responsible for implementing and enforcing this policy. The policy is reviewed on a yearly basis.