Holmen’s whistleblower function and these rules seek to ensure:
- an opportunity for employees and other stakeholders to inform Holmen of serious improprieties within the Group,
- that the information submitted is handled correctly in line with the legislation and regulations in force,
- that every person who informs Holmen of serious improprieties in good faith is protected from reprisals.
As information submitted may involve being notified that a person has, or may have, committed a crime, the provisions of the Swedish Personal Data Act (PDA) and particular regulations issued by the Swedish Data Protection Authority must be complied with. Under these provisions, the whistleblower function may only handle information regarding serious improprieties committed by persons who have a key position.
Serious improprieties means serious misconduct concerning accounting, internal accounting controls, auditing, bribery, serious environmental crimes, major deficiencies in workplace health and safety, serious forms of discrimination and harassment or other serious improprieties concerning the vital interests of the company or the Group or the life or health of individual persons.
Persons who have a key position refers to people in key positions or leading posts within the Group, i.e. people who can affect the business’ risk and security situation through their role and their authorisation. Examples include people who have HR responsibilities or who are authorised to handle large amounts of money on behalf of the company. It can also concern people responsible for purchasing, sales, investments, accounting, payments, permits, IT systems, health and safety and the environment.
Information judged to fall outside the areas described above will not be processed within this whistleblower function. Such an assessment, however, does not prevent the whistleblower from submitting the information through other channels, such as their manager (if the whistleblower is an employee), the HR department or another responsible person within the Group.
Confidentiality and anonymity
Holmen will treat all questions and issues in confidence. Exceptions may be made if this is necessary for the issue to be investigated thoroughly and fairly.
Discrimination or reprisals against a person who in good faith informs the company of illegal or unethical behaviour will not be tolerated.
Information can be provided anonymously but Holmen encourages the whistleblower to provide an e-mail address or other contact details so that contact can be maintained throughout the investigation. Continuing the investigation may be more difficult if the source of information cannot be identified for follow-up questions.
Things to remember when submitting information
A report should contain as many facts as possible to facilitate investigation of the issue. A report which cannot be investigated or corroborated will not lead to further examination.
Whistleblowers must be aware that the information submitted may result in decisions that affect employees at Holmen and also other parties that are involved in the case. It is therefore of the utmost importance that information is submitted in good faith and that it is correct to the best of the whistleblower’s knowledge.
Handling information submitted
Holmen is to ensure that all information is processed in line with the legislation and regulations in force. Where the information is judged to fall within the definition stated above, an appropriate investigation is to be carried out and reasonable measures to ensure confidentiality are to be taken. The number of people who come into contact with the matter is to be limited.
The information submitted is received by two appointed Reviewers. The Reviewers examine the issue and independently of each other make an initial assessment of whether the matter can be handled within the whistleblower function. If this is the case, an assessment is made of the severity and credibility of the issue reported. The Reviewers must then take appropriate measures which may involve handing the case over to the Supervisory Group. The Supervisory Group comprises three people with differing expertise who are responsible for ensuring that an appropriate investigation is carried out, which may be done by appointing special Investigators.
Once an assessment has been made, the Reviewers and the Supervisory Group may decide to withdraw the case and deregister it from the whistleblower function. They may also take measures immediately or pass the issue on to another resource at Holmen, to Holmen’s senior management or to the police, depending on the severity of and the extent of the impropriety.
At every step of the process, feedback will be provided to the whistleblower (provided that they submitted contact details).
Holmen is to ensure that if a whistleblower so requests, the whistleblower is given an extract from the data register to check the information recorded about him or her. Furthermore, Holmen must ensure that information that is incorrect, incomplete or misleading is corrected if a whistleblower so requests.