Avidly Plc

Whistleblowing Policy



1. What is whistleblowing, and why is it important?

Avidly strives to achieve transparency and a high level of business ethics. Our whistleblowing service offers a possibility to alert the organisation about suspicions of misconduct in a confidential way. It is an important tool for reducing risks and maintaining trust in our operations by enabling us to detect and act on possible misconduct at an early stage. Whistleblowing can be done openly or anonymously. In cases of alleged criminal offences, the non-anonymous whistleblower will be informed that his/her identity may need to be disclosed during judicial proceedings.

2. When to blow the whistle?

The whistleblowing service can be used to alert us about serious risks of wrongdoing affecting people, our organisation, the society or the environment.

Reported issues include criminal offences, irregularities and violations or other actions in breach of EU or national laws within a work-related context, for example:

  •  Corruption and financial irregularities; for example, bribes, unfair competition, money laundering, fraud, conflict of interest
  •  Health and safety violations; for example, workplace health and safety, product safety, serious discrimination and harassments that are against the law
  •  Environmental violations; for example, illegal treatment of hazardous waste
  • Privacy violations; for example, improper use of personal data

Employees are asked to contact their supervisor or manager for issues relating to dissatisfaction in the workplace or related matters, as these issues cannot be investigated in the scope of whistleblowing.

A person who blows the whistle does not need to have firm evidence for expressing a suspicion. However, deliberate reporting of false or malicious information is forbidden. Abuse of the whistleblowing service is a serious disciplinary offence. 

3. How to blow the whistle?

We use an anonymous and confidential external partner to guarantee the confidentiality of messaging. With the help of confidential messaging through the whistleblower reporting channel Avidly employees or external partners or stakeholders are able to leave their report to the whistleblowing team: https://report.whistleb.com/avidly

4. Confidentiality and anonymity

All messages received will be handled confidentially. The whistleblowing channel is administered by WhistleB, an external service provider. All messages are encrypted. To ensure the anonymity of the person sending a message, WhistleB deletes all metadata, including IP addresses. The person sending the message also remains anonymous in the subsequent dialogue with responsible receivers of the report.

5. The investigation process

THE WHISTLEBLOWING TEAM

Access to messages received through our whistleblowing channel is restricted to appointed individuals with the authority to handle whistleblowing cases. Their actions are logged and handling is confidential. When needed, individuals who can add expertise may be included in the investigation process, upon consent from the whistleblower in case the identity of the reporting person is disclosed. These individuals can access relevant data and are also bound to confidentiality. The whistleblowing team consists of/or reports may be disclosed to the following persons: Leena Talvensaari and Mari Floman

RECEIVING A MESSAGE

Upon receiving a message, the whistleblowing team decides whether to accept or decline the message. If the message is accepted, appropriate measures for investigation will be taken, please see Investigation below.

The whistleblower will receive an acknowledgment of receipt of the report within 7 days.

The whistleblowing team may not investigate the reported misconduct if:

  •  the alleged conduct is not reportable conduct under these Whistleblowing guidelines
  • the message has not been made in good faith or is malicious
  • there is insufficient information to allow for further investigation
  • the subject of the message has already been solved

If a message includes issues not covered by the scope of these Whistleblowing guidelines, the whistleblowing team should provide the reporting person with appropriate instructions with the help of confidential messaging through the whistleblower reporting channel.

The whistleblowing team will send appropriate feedback within 3 months upon the date of receiving the report.

INVESTIGATION

All messages are treated seriously and in accordance with these Whistleblowing guidelines. 

  •  No one from the whistleblowing team, or anyone taking part in the investigation process, will attempt to identify the whistleblower.
  • The whistleblowing team can, when needed, submit follow-up questions via the channel for anonymous communication. 
  • A message will not be investigated by anyone who may be involved with or connected to the wrongdoing.
  • Whistleblowing messages are handled confidentially by the parties involved.
  • Corporate or external expertise may be included in the investigation upon consent from whistleblower.

5. Protection and privacy

WHISTLEBLOWER PROTECTION

A person expressing genuine suspicion or misgiving according to these guidelines will not be at risk of losing their job or suffering any form of sanctions or personal disadvantages as a result. It does not matter if the whistleblower is mistaken, provided that he or she is acting in good faith.

Subject to considerations of the privacy of those against whom allegations have been made, and any other issues of confidentiality, a whistleblower will be kept informed of the outcomes of the investigation into the allegations.

Processing of personal data 

This whistleblowing service may collect personal data on the person specified in a message, the person submitting the message (if not sent anonymously) and any third person involved, in order to investigate facts on the declared misdeeds and inappropriate behaviour eligible under our code of conduct or internal rules. This processing is based on statutory obligations and the legitimate interest of the controller to prevent reputational risks and to promote an ethical business activity. The provided description and facts under this processing are only reserved to the competent and authorized persons who handles this information confidentially. The whistleblower may exercise rights of access, of rectification and of opposition, as well as of limited processing of personal data in accordance with the local data protection legislation. These rights are subject to any overriding safeguarding measures required to prevent the destruction of evidence or other obstructions to the processing and investigation of the case. Data is stored within the EU.

For any further questions or complaints please address your request to Leena Talvensaari.

Deletion of data

Personal data included in whistleblowing messages and investigation documentation is deleted when the investigation is complete, with the exception of when personal data must be maintained according to other applicable laws. Permanent deletion is carried out 30 days after completion of the investigation. Investigation documentation and whistleblower messages that are archived will be anonymised under GDPR; they will not include personal data through which persons can be directly or indirectly identified. 

Personal data controller: 

Avidly Plc responsible for the personal data processed within the whistleblowing service.

Personal data processor: 

WhistleB Whistleblowing Centre Ab (World Trade Centre, Klarabergsviadukten 70, SE-107 24 Stockholm) responsible for the whistleblowing application, including processing of encrypted data, such as whistleblowing messages. Neither WhistleB nor any sub-suppliers can decrypt and read messages. As such, neither WhistleB nor its sub-processors have access to readable content.

 

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