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About Signicat

Whistleblower Policy

At Signicat, our work ethics and behavior are guided by our core values TRUST and our Code of Conduct. Together, these two build the foundation of how representatives of Signicat shall treat colleagues and customers, to ensure a good working environment.

The Whistleblower Policy has been established to enable for Signicat representatives to address any misconduct against the core values or Code of Conduct in a secure and appropriate manner.

Scope
Signicat would like to encourage its representatives to report any instances of suspected corrupt, illegal, unethical, fraudulent or undesirable conduct involving the Company’s business.

This policy applies to any person who is, or has been, any of the following types of representatives for the Company:

  • Employee (permanent, fixed-term, zero-hour, intern).
  • Leader.
  • Consultant (including sub-contractors and employees of contractors).
  • Board member.

This policy applies to all the above regardless of country and which legal entity in Signicat one belongs to.


Reportable conduct
Reports or disclosure under this policy may be made if there are reasonable grounds to believe that an employee, leader, consultant, board member or other person who has business dealings with the Company, has gone against the company’s values and Code of Conduct by one or more of the following conducts:

  • Dishonest, fraudulent or corrupt.
  • Financial malpractice (including corruption).
  • Breaches of security routines.
  • Illegal (theft, use of or dealing illicit drugs, violence, threatening behavior, criminal property damage, rape).
  • Unethical behavior that violates the Company’s ethical and internal values and policies (TRUST and Code of Conduct, bullying, harassment, discrimination).

Reports that are not defined as reportable conduct will not qualify for protection under the law. The Company will make a judgement if a report falls under reportable conduct or not. If a report does not fall under reportable conduct, the Company will take into consideration keeping the anonymity as long as possible.

For the avoidance of doubt, personal work-related grievances do not fall under reportable conduct.

Address a misconduct
If you are aware of that a misconduct has occurred, Signicat expects you, as a representative of the Company, to address it under this policy.

Reports can be made in writing, verbally or at a meeting (digital or face-to-face).

Internal reporting
If you would like to be anonymous, you make a written report in our HR-platform Hibob under “Your Voice”. You will be able to choose to whom you would like your report to be sent.

Important to know is that regardless of who you choose, you will remain anonymous.

External reporting
If you do not like to be anonymous you can make a written statement, verbal statement or present the misconduct during a meeting. You can still use “Your Voice”-channel and add your name. Reporting instances are:

  • Any member of the People & Culture team.
  • Closest manager.
  • 2nd level manager.
  • Safety representative.
  • The Chief Information Security Officer (CISO).
  • Trade Union representatives (if you are a member).
  • The occupational Health Services (if your site is related to one).

Requirements for the rapporteur
The report must be made in good faith and should not be personally motivated. The notification must be proper, and should not be personally motivated. Criticism based on one's own political or ethical beliefs is not covered by the right to notify.

Whistleblowers have the right to remain anonymous. Anonymous notifiers cannot naturally be kept informed of the case.

Requirements for the receiver
The report and the rapporteur shall be treated with respect and be kept anonymous if the requirements are met. If the requirements are not met, anonymity shall be kept if needed.

Investigation of misconduct
All reports shall be investigated. The receiver has the right to intervene and come up with counter arguments. To conduct a qualitative investigation, the receiver might need to involve other instances, for example HR. The rapporteur will be informed if this is needed and who else will be involved.

When the case is completed, the rapporteur shall be informed of the outcome.

No retaliation
It goes against the Company’s values to retaliate against anyone who has, in good faith, addressed a misconduct. If retaliation is made against someone who has done a report in good faith, that would be considered acting against this policy and that person will be subject to disciplinary action which may lead to termination of the employment.

Privacy and confidentiality
If the requirements of the reportable conduct are met, the identity of the whistleblower shall not be revealed to anyone unless it is needed to investigate and close the case.

Publication

This policy is published both in the Company’s internal communication channels and externally on https://www.signicat.com/.