The whistleblower policy explains how the whistleblower system works at Holmris B8. The policy further aims to ensure that potential misconduct reports are not withheld due to a lack of clarity on the whistleblower system.
Holmris B8’s Whistleblower system
Holmris B8 has established a whistleblower system following the EU Directive 2019/1937.
The Whistleblower includes Holmris B8 and all subsidiaries.
Holmris B8’s whistleblower system is operated by WhistleSystem ApS, ensuring a completely anonymous and secure process for the whistleblower. The whistleblower system shall be used if employees or other stakeholders experience serious misconduct or offenses in relation to Holmris B8.
The types of matters that can be reported are further described in the whistleblower policy under “What can be reported?
Holmris B8 encourages individuals who experience misconduct or legal violations to contact their immediate manager and report the incident. However, this is not always the most appropriate course of action and may result in reports not being properly handled. Therefore, Holmris B8 has established a whistleblower system to ensure that, in cases where individuals do not wish or are unable to approach their immediate manager, or prefer to remain anonymous, they can still report the misconduct.
Reports can be submitted by anyone who has access to the scheme. At Holmris B8, this includes both internal and external stakeholders who have become aware of a violation.
A whistleblower report may concern individuals, situations, or incidents. The individuals who can be reported include, in principle, all stakeholders, provided that the report meets the criteria outlined under “What can be reported?” below and relates to Holmris B8.
Holmris B8 has appointed the following administrator team:
- Trine Skov Storgaard (Holmris B8)
- Flemming Ib Windfeld (Holmris B8)
- Peter Johansen (Mentha)
The following ESG representative is kept informed:
- Stephanie Faber Dam (Holmris B8)
Each case received is registerede, and the number of reports is disclosed in Holmris B8´s Sustainability Report.
What can be reported?
The whistleblower system can only be used to report serious misconduct or violations. Subjects such as cooperation difficulties, dissatisfaction with facilities, or dissatisfaction with conditions cannot be reported through the whistleblower system. In such cases,
individuals are advised to contact their immediate manager.
Examples of subjects that can be reported through the whistleblower system include, but are not limited to, the following points:
- Breaches of public procurement
- Money laundering
- Financial crime
- Product safety
- Environmental protection
- Radiation protection and nuclear safety
- Food and feed safety, animal health and animal welfare
- Public health
- Sexism
- Sexual harassment
- Physical violence
- Discrimination
- Occupational health and safety
- Consumer protection
- Protection of privacy and personal data, as well as the security of network and information systems
- Violation affection the Union´s financial interests as refereed to in Article 325 of the TFEU and further specified in relevant EU measures
However, it is Holmris B8’s policy that we would rather have one report too much than one too little, to ensure that we receive all relevant reports. This means that if you are unsure whether you report can be reported under the whistleblower legislation, you are encouraged to submit the report.
How do you report?
Reports are sent through WhistleSystem.
Whistleblowers can access the system and report as follows:
- Go to Holmris B8’s Whistleblower System.
- Fill the form with the necessary information and documentation, so the administrator team can process the report effectively.
The report is completely anonymous. WhistleSystem is the only channel at Holmris B8 where misconduct can be reported anonymously.
Reports can be submitted by all relevant stakeholders with whom Holmris B8 has shared access information to the system.
After the report is submitted, a unique report ID will appear, which must be saved and kept in a safe place. You can log in and reopen your report with your report ID. This allows you to start an anonymous dialog, send further documentation, and answer clarifying questions from the administrator team. Holmris B8 encourages the whistleblower to log in regularly after the report has been submitted to respond to any follow-up questions.
Please see the user manual for a detailed description of the reporting process.
How are reports processed?
The reports are processed by Holmris B8’s administrator team.
The process proceeds as follows:
- The administrator team will notify the whistleblower that the report has been received within 7 days.
- The administrator team assesses and categorizes the report and conducts an initial investigation. At this stage, it is possible that the administrator team needs more information or documentation from the whistleblower. The team will start an anonymous dialogue with the whistleblower through the system.
- The processing of the report is based on the type and severity of the report. Initially, the report is processed internally. In case of particularly severe misconduct or violations, the authorities can be involved in the investigation.
- The whistleblower is informed of the actions taken within 3 months of the submission of the report. In long-term cases, the whistleblower is updated on a regular basis.
- The reports are stored for as long as necessary to meet requirements arising from the Whistleblower Act, including registration and documentation obligations. The purpose of the storage may be based on legal evidence or if there is reason to believe that the report may be strengthened by subsequent reports received (linking).
Retaliation
The directive states that whistleblowers cannot be punished for reporting misconduct or violations. Thus, the whistleblower should not be concerned about private or career consequences following the report. If the report is relevant under the Whistleblower Directive, the whistleblower will not be punished by Holmris B8 after submitting the report.
This includes the following penalties (retaliation):
- Termination
- Suspension
- Degradation
- Failed promotion
- Change in working time and tasks
- A decline in wages
- Intimidation
- Harassment
- Social exclusion at work.
Holmris B8’s whistleblower policy aims to encourage greater transparency and security for all employees and stakeholders.
Security
The system utilizes several security measures that protect the whistleblower and the system in general. Some of these include:
- Full encryption throughout the process
- ISO 27001 certified (Information security)
- ISO 27701 certified (GDPR compliance)
- ISO 27001 approved servers in Europe
- Schrems II compliant
- SSL technology
- Shield and WAF on the application level
- Two-factor authentication at administrator level’
- Redundancy at both application and database level
- Architecture built on the latest technology
- Continuous AI monitoring
- No IP logging
External whistleblower channels
We recommend reporting directly to Holmris B8’s whistleblower system, as in most cases the report can be processed most effectively internally. However, it is also possible to report to external whistleblower channels provided by the government. These can be found by searching the internet for the relevant government agency name followed by “whistleblower”.
Moreover, external whistleblower channels in the EU, including the European Commission, the European Anti-Fraud Office (OLAF), the European Maritime Safety Agency (EMSA), the European Aviation Safety Agency (EASA), the European Securities and Markets Authority (ESMA) and the European Medicines Agency (EMA).