Whistleblower Policy

HAE Koncern’s whistleblower scheme is intended to increase the opportunity for HAE Koncern’s current and former employees, suppliers, and customers to speak up about reprehensible matters in the workplace without fear of negative consequences. The purpose of the whistleblower scheme is thus to ensure openness and transparency in relation to potential legal violations and serious irregularities.

HAE Koncern’s whistleblower scheme is to be regarded as a supplement to the direct and daily communication in the workplace concerning errors and unsatisfactory conditions, etc. The scheme is also a supplement to existing options such as contacting your immediate manager or the HR department. HAE Koncern encourages the use of the whistleblower scheme so that potential violations can be addressed quickly and effectively internally. However, the whistleblower is free to choose whether to submit a report through the workplace whistleblower scheme. HAE Koncern’s whistleblower scheme does not exclude the possibility of reporting through external channels such as supervisory authorities.

HAE Koncern’s whistleblower unit

Reports submitted to HAE Koncern’s whistleblower scheme are forwarded by the whistleblower unit and processed by the individual companies’ whistleblower unit or HR department. Questions concerning specific reports must be directed to the relevant whistleblower unit or HR department.

General questions regarding HAE Koncern’s whistleblower scheme may be directed to:

Morten Brink Smidt
Sales Consultant
Mobile: +45 20 54 12 26 – Email: mbs@kundehus.dk

HAE Koncern’s whistleblower scheme uses its own system for registering and processing reports.

You will be asked to provide an email address when submitting a report. Your email address will be used to keep you informed about the processing of your report, to request additional information or clarification, and to inform you when your report has been closed.

If you wish to remain completely anonymous throughout the reporting process, we recommend that you create a temporary anonymous email address that you can check regularly during the process.

Depending on the content and nature of the report, the processing may also involve assistance from an external party, such as a lawyer or auditor.

Information that can be reported

HAE Koncern’s whistleblower scheme can be used to report information about serious violations or other serious matters that may not necessarily constitute a specific breach of law. Reports may concern matters that have occurred or may occur within HAE Koncern.

A legal violation or other matter will generally be considered serious if it is in the public interest to bring it to light. Minor violations are not covered, nor are breaches of ancillary provisions. Reports concerning the whistleblower’s own employment conditions are generally not covered, unless they involve sexual harassment or serious harassment.

Information about other matters, including violations of internal guidelines of a less serious nature, such as rules on sick leave, dress code, or other HR-related conflicts in the workplace, will generally not be considered serious violations and should therefore not be reported through HAE Koncern’s whistleblower scheme. Such matters should instead be reported to the immediate manager, HR department, or a union representative in accordance with applicable guidelines.

It is assumed that the whistleblower acts in good faith regarding the accuracy of the information.

Appendix 1 provides examples of serious legal violations, serious matters, and information that is not covered by the whistleblower scheme.

Submitting a report

Reports to HAE Koncern’s whistleblower scheme must be submitted via the Whistleblower Portal using the company code found in your employment documents, contract, or staff handbook. Follow the instructions in the portal.

You will be asked to provide an email address when submitting a report. If you wish to remain completely anonymous throughout the process, we recommend creating a temporary anonymous email address that you can check regularly. If you would like to know how your email address will be used, please read more under “HAE Koncern’s whistleblower unit”.

Who can submit information through the whistleblower scheme

The following groups may use HAE Koncern’s whistleblower scheme:

Current or former employees of HAE Koncern*
Members of the company’s board of directors
Members of the board of directors of another company within HAE Koncern
Shareholders
Suppliers, customers, and other business partners

*Must have been employed within the last five years, whether in paid or unpaid work.

Processing of reports

Upon receiving a report, HAE Koncern’s whistleblower unit will acknowledge receipt within seven days. This will be done via the email address you provided.

The whistleblower unit will then carefully follow up on the report. The content and nature of the report determine how follow-up is carried out.

Initially, the whistleblower unit will assess whether the report falls within the scope of the whistleblower scheme. If the report falls outside the scope or is manifestly unfounded, it will be rejected. The whistleblower will be informed accordingly.

If the report falls within the scope of the law, it will be processed. This may include, depending on the nature of the report, collecting additional information internally within the group. In some cases, this may also involve further dialogue with the whistleblower.

Examples of follow-up actions:

Initiation of an internal investigation within the company
Notification of the company’s senior management or board of directors
Reporting to the police or relevant supervisory authority
Closure of the case due to lack of or insufficient evidence

Within three months from the acknowledgment of receipt, the whistleblower unit will provide feedback to the whistleblower. Depending on the content and nature of the report, this may include information about measures taken or planned and the reasons for the chosen follow-up.

If it is not possible to provide feedback within the deadline, HAE Koncern’s whistleblower unit will inform the whistleblower accordingly and indicate whether further feedback can be expected. This may be the case, for example, if an internal investigation has been initiated and cannot be concluded within the deadline.

Feedback must comply with applicable legislation, including data protection laws. This means there must be a legal basis for disclosing sensitive information. The specific information that can be shared depends on a concrete assessment.

Confidentiality and processing of information

Employees connected to HAE Koncern’s whistleblower unit are subject to a special duty of confidentiality regarding the information included in reports.

The duty of confidentiality applies only to the information included in the report itself. If a report leads to the initiation of a case, additional information collected in connection with that case is not covered by this duty. HAE Koncern’s whistleblower unit will, to the greatest extent possible, process reports confidentially.

Information from a report is processed in accordance with Section 22 of the Danish Whistleblower Act and the General Data Protection Regulation and Danish Data Protection Act. HAE Koncern’s whistleblower unit may process personal data, including sensitive data and information about criminal offences, if necessary to handle a report received through the whistleblower scheme.

Information from a report may be disclosed where relevant, for example for the purpose of follow-up. The whistleblower will be informed before disclosure of their identity, unless such notification would jeopardise a related investigation or legal proceedings. This may be the case, for example, if there is a risk that evidence could be concealed or destroyed, that witnesses may be influenced, or if there is suspicion that the whistleblower knowingly submitted a false report.

Protection of whistleblowers

A whistleblower may not be subject to retaliation, including threats or attempts of retaliation, because they have submitted a report to HAE Koncern’s whistleblower unit or an external whistleblower scheme. Furthermore, the whistleblower may not be prevented or attempted to be prevented from submitting a report.

Retaliation is understood as any form of adverse treatment or consequence as a reaction to an internal or external report that causes or may cause harm to the whistleblower.

A whistleblower cannot be held liable for reporting confidential information if they had reasonable grounds to believe in good faith that the information was necessary to reveal a serious legal violation or serious matter.

Attempts by employees or management of HAE Koncern to prevent a whistleblower from reporting or to retaliate against a whistleblower who has reported in good faith will result in employment-related consequences.

Further information

The Danish Ministry of Justice has prepared guidance for individuals who wish to submit or are considering submitting information as a whistleblower. The guidance provides a general description of the Whistleblower Act, reporting channels, whistleblower rights, and protection of whistleblowers. The guidance can be found on the Ministry of Justice website at www.jm.dk

Appendix 1

Examples of serious legal violations

Violations of the Danish Criminal Code that will generally fall within the scope:

• Bribery, cf. Section 144 of the Criminal Code
• Forgery of documents, cf. Section 171
• Hacking, eavesdropping, recording of conversations between others, etc., cf. Section 263
• Theft, cf. Section 276
• Embezzlement, cf. Section 278
• Fraud, cf. Section 279
• Computer fraud, cf. Section 279a
• Breach of trust, cf. Section 280
• Extortion, cf. Section 281

Violations of special legislation or other legislation generally covered:

• Violations of tax legislation
• Breach of confidentiality obligations
• Violations of the Bookkeeping Act
• Violations of the Freight Transport Act, cf. Sections 17–17b
• Violations of the Aviation Act, cf. Section 149
• Failure to comply with a statutory duty to act
• Violations of rules on use of force
• Serious or repeated breaches of administrative law principles, including the principle of investigation, requirement of objectivity, prohibition of misuse of power, and proportionality (subject to the remarks on minor violations below)
• Deliberate misleading of citizens and business partners

Harassment

• Sexual harassment, cf. Section 1(4) of the Equal Treatment Act
• Serious harassment, e.g. based on race, gender, colour, national or social origin, political or religious affiliation

Examples of serious matters

Matters generally considered serious:

• Failure to comply with professional standards that may pose a risk to people’s safety or health
  Serious or repeated violations of the workplace’s internal guidelines on matters such as business travel, gifts, or accounting (subject to the remarks on minor violations below)
• Serious errors and serious irregularities related to IT operations or IT system management
  Special cases where minor cooperation difficulties involve significant risks and therefore constitute a serious matter

Examples of information not covered by the scheme

• Information of a trivial nature, information about other matters including violations of internal guidelines on sick leave, smoking, dress code, or ancillary provisions such as failure to comply with documentation requirements.
  Information concerning the whistleblower’s own employment conditions, including conflicts between employees, cooperation difficulties, or matters covered by the labour law system, unless they concern sexual harassment or other serious harassment.