Whistleblowing
1. The Company’s internal report channels
Every employee, consultant and other people that are participating or have participated in the business of the Company and that has received information about the Company has the right to, anonymously and without reprisal, discriminating actions or other forms of mistreatment, report any form of wrongdoings or violations, or suspected violations by employees or functions in the Company. This shall be done through the Company’s whistleblowing channels.
The Company’s whistleblowing channels are provided by Advokatfirman MORE Evander KB, which the Company has appointed as its whistleblowing function and receiver of any reports.
1.1. Reporting
Reporting of any wrongdoings or violations, or suspected violations that is of public interest shall be made to Advokatfirman MORE Evander KB (”Whistleblowing function”) via e-mail, telephone, letter or in any other way that is possible.
- Email: whistleblower@amelegal.se
- Letter: Advokatfirman MORE Evander KB Box 7330 103 90 Stockholm
- Telephone: 08-200 610
- Visiting Address Kungsgatan 29, 3 tr 111 56 Stockholm
1.2. Routine for handling reports
The Whistleblowing function will receive the report and confirm it to you within seven days upoon receipt. The Whistleblowing function will indicate how long the approximate time of investigation to be expected and also state if an investigation will be made. When the investigation is complete, within three months from receipt, the Whistleblowing function will notify you. If a notification cannot be sent within the three months, a notification with reasons for this delay will be sent to you.
The Whistleblowing function shall assess in each case if any authority or the Police should be involved. The Whistleblowing function will also leave recommendations to the Company together with propositions of possible solutions of the reports.
1.3. Confidentiality
The Whistleblowing function will make sure that your identity is not revealed to unauthorized people or functions. You may also state that you do not wish to remain anonymous but the Whistleblowing function will remain confidential with your identity and only reveal it if it is for the benefit of the investigation or you. The Whistleblowing function will inform you of what people that have knowledge of your identity, if applicable.
1.4. Prohibition against reprisal or discriminating actions.
Neither the Company, other employees or the Whistleblowing function may take any discriminating actions or other forms of mistreatment against you or anyone who is aiding you in your report. This is also the case if your report was because of misjudgments or ignorance from you.
2. External reporting channels
Any reports about any wrongdoings in the Company can also be reported to authorized Swedish authorities through external reporting channels. When this is made, it is called external whistleblowing. The report could be about events or actions that are illegal, unethical or unreasonable. Wrongdoings within financial services, products and markets as well as AML-irregulations can be reported to:
- Swedish Financial Supervisory Authority
- Email: visselblasare@fi.se
- Letter: Finansinspektionen Box 7821 103 97 Stockholm
- Telephone: 08-408 986 70
3. Freedom of communcation and procurement
The person reporting has a freedom of communication and a freedom of procurement in accordance with Swedish law. This also applies for certain confidential information and the Company is not allowed to investigate who has reported the information.
4. Processing of Personal data
When you report of any wrongdoings to the Whistleblowing function, the Whistleblowing function will process personal data about you, in accordance with applicable law. This is done in order to receive your report, stay in contact with you during any investigation and to report back to you. The legal basis for this is because the task performed is in the public interest. Your personal data will be archived in accordance with applicable law.
You have the right to contact the Whistleblowing function to receive information about the personal data that the Whistleblowing function has received from you or if you want anything to be corrected. You can also, under certain conditions, request the Whistleblowing function to limit the processing, object or request deletion of your personal data. For any questions about this, send an e-mail to: info@amelegal.se.
If you have any complaints about the processing of your personal data, you can complain to Integritetsskyddsmyndigheten (IMY): https://www.imy.se/