Whistleblowing Policy
1. Introduction
We value openness and transparency throughout the Awardit Group (Awardit AB, MBXP, Awardit Direkt GmbH, Awardit Solutions GmbH, Awardit Marketing GmbH and Awardit Loyalty GmbH). In the event of misconduct within our organisation, we encourage you to report it through our whistleblowing channel, which allows you to communicate confidentially and anonymously.
1.1 Who can report?
The whistleblowing channel can be used by individuals who have an active or past work-related relationship with the Awardit Group, such as applicants, employees, trainees, volunteers, members of management, active shareholders and self-employed individuals working within the Group.
1.2 What to report?
If you become aware of misconduct in a work-related context or have reasonable grounds for serious suspicion, we urge you to submit a report via the Awardit Group reporting channel. Please only submit a report if you also have reasonable grounds to believe that the information you have received is true. However, it is not necessary to be able to provide evidence of the misconduct as long as you are acting in good faith.
2. Misconduct
2.1 Misconduct of public interest
Any behaviour that could have a serious negative impact on the business and/or operations of the Awardit Group is considered misconduct. This also applies to any behaviour that has a serious negative impact on the working environment for employees and/or business partners of the Awardit Group. In addition, any other serious misconduct that is of public interest should also be reported.
Examples of misconduct that can be reported through this whistleblowing channel include
- Deliberate false accounting or other financial crime.
- Theft, corruption, vandalism, fraud, embezzlement or hacking.
- Serious forms of discrimination or harassment.
- Other serious misconduct related to the fundamental interests of the Awardit Group.
For other types of personal complaints that are not of public interest (such as disputes or complaints about the workplace or working environment), we encourage you to contact your line manager, the HR department or the Safety Officer.
2.2 Misconduct contrary to EU law
It is also possible to report information about misconduct that contravenes EU laws or regulations in a work-related context. If you suspect that this is the case, please refer to the scope of the Whistleblower Directive in Article 2 and Annex Part 1 for applicable laws.
3. Reporting
3.1 Written report
Our digital whistleblower channel is available at any time via the following link
https://awardit.visslan-report.se
Please describe what has happened as thoroughly as possible so that appropriate action can be taken. It is also possible to attach additional evidence, such as written documents, pictures or audio files. However, this is not mandatory.
3.1.1 Sensitive personal data
Please do not include any sensitive personal information of individuals in your report, unless this is absolutely necessary to describe your case. Sensitive personal data is information about: ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation, and genetic and biometric data that can be used to uniquely identify an individual.
3.1.2 Anonymity
You can remain anonymous throughout the process without jeopardising your legal protection. However, you also have the option of disclosing your identity in the strictest confidence. In some cases, anonymity can make it more difficult to trace the misconduct and the measures to be taken. If such a case exists, we may ask you later to disclose your identity to the case manager responsible in the strictest confidence.
3.1.3 Follow-up of misconduct and registration
After your report, you will receive a sixteen-digit code that you can use to log in in future. It is important that you keep this code, otherwise you will not be able to access your report. If you lose the code, you can submit a new report with reference to the previous report.
You will receive confirmation that the case manager has received your report within seven days. The responsible case manager is the independent and autonomous party who receives reports in the reporting channel. The contact details of the case manager are given in section 6. If you have any questions or concerns, you and the case manager can communicate via the reporting platform's integrated anonymous chat function. You will receive feedback within three months on the measures planned or already implemented on the basis of your report.
It is important that you log in regularly with your sixteen-digit code in order to answer any follow-up questions from the case manager. The reason for this is that in some cases the reported misconduct cannot be followed up if you, as the person making the report, do not respond to such follow-up questions from the case manager.
3.2 Verbal report
It is also possible to make a verbal report by uploading an audio file as an attachment when creating a report. This is done by selecting that you have evidence for the report and uploading an audio file in the appropriate field. The audio recording should describe the same facts and details as a written report.
In addition, a physical meeting with the case manager can be requested via Visslan. The easiest way to do this is either by requesting it in an existing report or by creating a new report with a request for a physical meeting
3.3 External reporting
We always encourage you to report misconduct internally first. However, if difficulties arise with the internal report, it is deemed inappropriate or no action is taken afterwards, it is also possible to make an external report instead. In this case, we recommend that you contact the competent authorities or, if applicable, the relevant EU institutions, bodies or agencies.
4. What rights do I have?
4.1 Right to confidentiality
During the processing of the report, 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 we are required to do so by applicable law, and we will ensure that you are not subject to retaliation.
4.2 Protection from reprisals or retaliation
In the event of a report, there is protection from negative consequences for reporting misconduct in the form of a prohibition on reprisals and retaliation. This protection also applies in relevant cases to people in the workplace who support the reporting person, as well as to colleagues and relatives in the workplace and legal entities for which you work, are employed or otherwise associated.
This means that threats of retaliation and attempts at retaliation are not permitted. Examples include termination, forced reassignment, imposed disciplinary action, threats, discrimination, listing in your industry or the like based on the report. Even if you were identified and subjected to retaliation, you would still be covered by the protection as long as you had reasonable grounds to believe that the reported misconduct was true and within the scope of the Whistleblower Act. Note, however, that no protection is provided if the information reported was accessed or obtained in a criminal manner.
4.3 Publication of information
The protection also applies to the publication of information. It is assumed that you have reported internally within the company and externally to a government authority or directly to the outside world and that no appropriate action has been taken within three months (six months in justified cases). The protection also applies if you had reasonable grounds to believe that there was an obvious risk to the public interest if you did not disclose the information, for example in an emergency. The same applies if there is a risk of retaliation for external reporting or it is unlikely that the misconduct will be remedied effectively, for example if there is a risk that evidence will be covered up or destroyed.
4.4 Right to see documentation when meeting with the case manager
If you submit your report by telephone or at a meeting, your report will either be recorded if you consent to such recording or recorded in a log that you can review, correct and approve.
5. GDPR and handling of personal data
We always do our best to protect you and your personal information. Therefore, we ensure that our handling of personal information is always in accordance with the GDPR.
In addition, all personal data without relevance to the case will be deleted and the case will only be stored for as long as necessary and appropriate.
6. Contact details
If you have any further questions regarding the handling of whistleblower cases, please contact
Cecilia Asp: cecilia.asp@awardit.com
Charlotte Norrby: charlotte.norrby@awardit.com
Medina Spahic: medina.spahic@awardit.com
Mikael Mellberg: mikael.mellberg@lindahl.se
Ellinor Söderberg: ellinor.soderberg@lindahl.se
For technical questions about the Visslan platform: clientsupport@visslan.com
6.1 Case manager
This Whistleblower Policy applies to Awardit AB, MBXP, Awardit Direkt GmbH, Awardit Solutions GmbH, Awardit Marketing GmbH and Awardit Loyalty GmbH.
6.1.1 Recipients of reports regarding Awardit AB (Sweden) are:
Name: Mikael Mellberg
Company/Position: Advokatfirman Lindahl KB, Lawyer/Partner
E-mail: mikael.mellberg@lindahl.se
Phone: +46 723 881 021
Name: Ellinor Söderberg
Company/Position: Advokatfirman Lindahl KB, Attorney/Associate
E-mail: ellinor.soderberg@lindahl.se
Tel: +46 768 543 224
6.1.2 Recipient of reports regarding MBXP (Denmark), Awardit Direkt GmbH, Awardit Solutions GmbH (Germany), Awardit Marketing GmbH/Awardit Loyalty GmbH (Austria) and/or unspecified locations:
Name: Cecilia Asp
Company/Position: Awardit, CHRO, Chief Human Resources Officer
Email: cecilia.asp@awardit.com
6.2 Contact details for Visslan (The Whistle Compliance Solutions AB)
For technical questions about the Visslan platform, you can contact Visslan directly.
E-mail: clientsupport@visslan.com
Switchboard: +46 10-750 08 10
More information about Visslan can be found on their website.