Proventia's whistleblowing channel
We comply with law and abide by the principles of good governance everywhere we operate. Responsibility, openness, honesty and trust are at the core of our Code of Conduct and part of our corporate culture. Our whistleblowing channel is an important part of our responsible operations.
What does whistleblowing mean?
Whistleblowing means that any illegal or unethical activities or misuse are reported. The purpose of the whistleblowing channel is to identify and rectify any deficiencies in our operations. Anyone submitting a notification must act sincerely and honestly.
For our employees
- We encourage our employees to primarily contact their supervisor.
- Through the whistleblowing channel, any suspected misuse can also be reported anonymously.
For our stakeholders
- In addition to our employees, our external stakeholders can anonymously report any suspected misuse or other violations through the whistleblowing channel. Misuse notifications are only processed in the whistleblowing channel.
- Any other notifications, including customer feedback and complaints, must be submitted through separate channels.
All notifications will be processed confidentially. Everyone participating in processing are bound by a confidentiality obligation. Notifications can be submitted anonymously or by entering the submitter's name. Notifications submitted in both ways will be processed confidentially. The identity of persons who submit notifications by entering their own name will only be known to designated individuals and everyone who is invited to investigate the matter as specialists.
The protection laid down the EU Whistleblower Directive (EU 2019/1937) and national legislation on whistleblowing is provided when misuse is discovered in conjunction with work and when a notification concerns public procurement, financial services, products or markets, the prevention of money laundering and terrorism, product safety and compliance, traffic safety, environmental protection, radiation and nuclear safety, food and feed safety, animal health and welfare, national health, consumer protection, privacy and personal data protection, or network and data system security.
Other types of misuse notifications will be investigated in accordance with other applicable law and the principles of good governance by protecting the notification submitter by best possible means.
How to submit a whistleblowing notification?
As a rule, you should submit your notification using Proventia´s whistleblowing channel.
You can submit your notification anonymously or by entering your name. The system enables communication with the notification submitter even if the notification was submitted anonymously. Notifications can only be accessed by those responsible for processing them.
Notifications will be investigated by a team appointed by Proventia, with its members being committed to storing and processing the data as required by law. If any of the team´s members is disqualified, they cannot participate in the processing of the case. The appointed team members can invite other Proventia employees or external specialists to process individual cases.
Those responsible for processing notifications assess notifications and the situation to determine whether the notification is within the scope of application of the whistleblower protection act. In unclear situations, the person submitting a notification must be asked whether their notification can be processed as customer feedback, for example, in which case whistleblower protection is not provided and personal data are not as confidential as in the case of misuse notifications.
Confirmation of receipt
Those who submit notifications will receive a confirmation of receipt from the whistleblowing channel within seven days of receiving their notification.
If a notification is not clearly a misuse notification that should be processed in the whistleblowing channel, the submitter will be notified of the transfer of their case to another process or responsible party. If a notification does not need to be transferred to another process or responsible party, the submitter will be notified that no further measures will be taken.
Assessing further investigation measures
When a misuse notification needs to be processed in the whistleblowing channel, those responsible for processing notifications submitted to the whistleblowing channel as appointed by Proventia will assess the further investigation measures required and invite other Proventia employees or external specialists to investigate the case.
If a notification is found to be accurate, those responsible for processing notifications will report the case to the CEO or the Chair of the Board of Directors to take action to investigate the violation.
Notifying the submitter of further measures
Those responsible for processing notifications submitted to the whistleblowing channel will notify the submitter of further measures within three months after sending the receipt of confirmation through the whistleblowing channel.
Information about further measures will be provided to the extent that is possible considering the three-month deadline, confidentiality and other factors.
Results and conclusions of investigations
As a result of the investigation, Proventia will decide on further measures and their implementation or determine that no further measures are required. Further measures may concern process development, agreements, HR activities, reporting the case as a crime, or legal proceedings. If possible, notification submitters will be notified of the final results of investigations.