Whistle-blowing Policy
At Plint we are committed to promoting an environment of transparency, integrity, and accountability. This Whistleblower Policy reflects our dedication to uphold these values and to ensure that any person connected to our operations feels confident to report any behavior or actions that may not align with our ethical and legal standards, without fear of retaliation or adverse consequences. This policy provides clear guidelines on how such concerns can be raised, the protection available to whistleblowers, and the processes that will be followed upon reporting.
Who can report?
Anyone who, in a work-related context, has obtained or accessed information about misconduct and belongs to one or more of the following categories within our organization:
a) employees,
b) individuals making an employment inquiry or applying for a job,
c) individuals applying for or performing volunteer work,
d) individuals applying for or undergoing an internship,
e) individuals otherwise available to perform or are performing work under the organization’s control and direction,
f) self-employed individuals applying for or executing assignments,
g) individuals available to join or are part of the organization’s administrative, executive, or supervisory bodies,
h) shareholders available to work or are active in the corporation, or
i) individuals who have previously belonged to any of the above categories.
Reportable matters
The whistleblower service should be used to report information concerning misconduct that is of public interest. Examples of typical misconduct include violations of laws and regulations, corruption, bribery, financial crimes, misuse of financial resources, and severe harassment. This also encompasses violations within a range of laws and provisions based on EU legal foundations that are considered to be of public interest.
When assessing whether a report is actually a whistleblower case as defined by law, the public interest aspect weighs heavily and must be assessed on a case-by-case basis.
Issue categories that could be assessed as a Whistleblower case is for example:
- Corruption and financial irregularities; for example, bribery, unfair competition, money laundering and fraud
- Intentional violations of legislation
- Environmental misconduct; for example, illegal handling of hazardous waste
- Serious and/or recurring bullying or harassment in the workplace that is not dealt with or investigated by the company in accordance with the Discrimination Act.
You don’t need to have evidence that your report is true; it is sufficient that you are acting in good faith concerning your concerns. However, the report must not be based on rumors or hearsay, and it is not permitted to lie or knowingly provide false information.
Misconduct that only affects the reporting person’s own working or employment conditions is normally not of public interest and should not be reported in the whistleblower channel. For these types of issues please use regular channels to inform immediate manager, the manager’s manager, HR, work environment representative or trade unions.
Incidents such as unauthorized access to confidential information, leakage, or suspicion of leakage of personal data, workplace incidents, theft etc. is also normally not of public interest and should not be reported as a whistleblower case. Incidents should be reported according to our Incident process.
Whistleblowers can submit their report by using this link right here
We utilize the services of Simployer &frankly, an independent third-party, to provide our whistleblower channel. Any reported issue is evaluated and managed internally by a Case manager at Plint.
- Reporting: Via Simployer &frankly’s reporting portal, accessible through the specified link. Here you can input your case in writing, voice record your concern, or request a physical meeting.
- Reception: Our Case Manager receives all reports and will make a first evaluation of the case. The first review will always include an assessment of whether or not it is a whistleblower case. However, this doesn’t mean that cases reported and deemed not to be a whistleblower case, according to the law, will be dismissed. These cases will still be managed but not necessarily as a whistleblower case.
- Follow-up: The Case Manager is responsible for initiating investigations and providing feedback to the whistleblower.
- Information Sharing: Relevant information may be shared with internal stakeholders such as the board, management team, or HR. The case manager decides the most appropriate first point of contact based on the nature of the case.
- Timeframes: You will receive an acknowledgment of your report within 7 days. Feedback on the case will be given within three months at the latest.
Feedback to Whistleblowers Even if we might not be able to provide all the details, we will acknowledge the whistleblower and inform them that an investigation has been conducted and give a brief account of the outcome or the follow-up actions taken.
Individuals who report concerns in good faith, as well as those assisting them, are safeguarded under whistleblower laws.
A reporting individual shall not be held accountable for breaching professional secrecy, provided that at the time of reporting, the individual had reasonable grounds to believe that such reporting was necessary to expose a misconduct. The protection applies under the same conditions when gathering information for reporting, unless the reporting individual commits a crime during the information gathering process. Please note that the freedom from liability do not grant the right to disclose documents or records from the organization.
Prohibition of taking preventive measures and reprisals
Plint does not have the legal right to:
1. obstruct or attempt to obstruct reporting, or
2. because of reporting take reprisals against
a) a reporting person,
b) someone at the company who assists the reporting person in the reporting,
c) someone at the company who is connected to the reporting person, such as a relative or colleague, or
d) a legal entity that the reporting person owns, works for or is otherwise connected with.
We are also not allowed to take reprisals because someone turns to their labor organization for consultation regarding reporting or to prevent or attempt to prevent such consultation.
We ensure that all reporting is handled confidentially but also enables anonymous reporting, where we cannot identify the person who reports.
When submitting a report, you will have the option to receive notifications about your case via email or SMS. If you choose to provide these contact details, they will be accessible to Simployer &frankly but remain undisclosed to Plint. However, this step is optional. Upon reporting, you’ll receive a unique ID that can be used to track the progress and any responses to your case without having to provide any contact details.
While our provider logs IP addresses in their system, they are never shared with Plint. For utmost assurance of anonymity, we recommend submitting your report from a device not provided by the company and outside the Plint network.
External reporting Procedures
The protections outlined above also apply when reporting externally to an authority. The authorities designated by the government have their own external reporting channels and procedures for receiving, tracking, and providing feedback on reports within their respective areas of responsibility. Such external reporting is overseen by the specific designated authorities, and our organization is not connected to these reporting channels.
For more information on what external reporting entails and which authority you should approach, refer to your country’s regulation on the protection of persons reporting misconduct. Additionally, you can submit your report to EU institutions, bodies, or agencies if the report pertains to union law. Detailed procedures can be found with the respective authority or EU entity.
Contact
If you have questions regarding the contents of this policy, or, you want to be informed about, change or delete your information, please reach out to info@plint.com
Plint AB
Org. no. 556630-3060
Östra Larmgatan 16
SE-411 07 Göteborg
Sweden