Whistleblowing

WHISTLEBLOWING - REPORTS OF VIOLATIONS

IBSA Nordic ApS encourages anyone who, in the context of work, has become aware of or suspect serious violations of the IBSA Code of Ethics, the IBSA Anti-Corruption Guidelines or other serious violation of the law or policies that could put IBSA Nordic ApS’ business or reputation at risk or that could cause damage to third parties, or the Whistleblower her- or himself.
 

REPORTING REQUIREMENTS
Each report must contain the following elements:

  • the personal details of the whistleblower, in the event that the whistleblower does not opt for being anonymous;
  • a clear and complete description of the facts being reported, to the extent known; 
  • if known, the circumstances of time and place in which they were committed;
  • if known, personal details or other elements (such as the qualification and the service in which a reported person carried out the activity) that allows for identification of the subject(s) who has/have carried out the reported facts;
  • an indication of any other persons who may be able to report on the facts being reported;
  • an indication of any documents which may confirm the validity of the facts being reported;
  • any other information that may be useful when assessing the facts reported.
  • It should be noted that:
  • reports based on mere rumours, or which are otherwise unreliable, will not be taken into account;
  • anonymous reports will only be taken into account if they meet the above requirements;
  • reports concerning disputes, claims or requests related to a personal interest of the whistleblower, that relate exclusively to the whistleblower’s individual employment relationship, including, but not limited to, labour disputes or friction between colleagues, are not allowed, unless such infractions are of a serious nature.
     

INTERNAL REPORTING CHANNELS
Reports can be submitted using one of the following internal reporting channels:

  • Mail: IBSA Nordic ApS, Kalvebod Brygge 45, 2nd floor, DK-1560 Copenhagen V, Att.: Whistlebloweransvarlig. 
  • Mark the letter “Confidential” / “Fortroligt” 
  • Web: https://ibsanordicwhistleblowing.whistlelink.com – Written or oral reports

Oral reporting is also permitted, at the request of the Whistleblower, through a direct meeting with the Whistleblower-responsible at IBSA Nordic ApS to be requested using the channels indicated above.

Each report will be evaluated to determine its suitability for further assessment. 
Reports will to the extent legally possible, be managed guaranteeing the confidentiality of the whistleblower and the prohibition of retaliation against the whistleblower. 

In the case of anonymous reports, the whistleblower may be asked to reveal his identity, which, to the extent legally possible, is with the guarantee of confidentiality and the protections provided for by whistleblower law of Denmark.

Be aware: Due to limitations of Danish law, the Company may not be able to provide full protection of the whistleblower in accordance with the whistleblower legislation. 

If a whistleblower does not feel sufficiently protected when using the Whistleblower Scheme of IBSA Nordic ApS, even if making an anonymous report, it is recommended to make use of the National Whistleblower Scheme, https://www.whistleblower.dk instead.


EXTERNAL REPORTING CHANNELS
The whistleblower may also make report through the National Whistleblower Scheme, which may be accessed at https://www.whistleblower.dk.

The use of the National Whistleblower Scheme is particularly recommended if the whistleblower does not feel sufficiently protected when using the Whistleblower scheme of IBSA Nordic ApS. 

Finally, public disclosure, e.g. through the press or electronic means or means of mass communication capable of reaching a large number of people can be used ONLY if one of the following conditions is met, of which the whistleblower must be able to have evidence:

  • the whistleblower has already made an internal and external report, or has directly made an external report and has not received feedback within the deadlines provided for; 
  • the whistleblower has reasonable grounds for believing that the issue, which the whistleblower wishes to disclose, may constitute an imminent or manifest danger to the public interest; 
  • the whistleblower has reasonable grounds to believe that external reporting may involve a risk of retaliation or may not be effectively followed up due to the specific circumstances of the case 

“Download here” the Whistleblowing Policy of IBSA Nordic ApS