Boston An independent LDT provider

Whistleblowing

Do you have something you want to tell us about?
We want to hear it!

We try to maintain an open and healthy culture, where every employee has a responsibility to follow applicable regulations and act ethically. Many situations can be solved by talking to each other immediately when they arise. Sometimes things can happen that require handling in a completely different way.

Regardless, it is important for us that problems or more serious issues are identified so that we as an organization have the opportunity to act. In more serious cases, such as various types of malpractice, or where there is a danger to health and life, it is important that this is identified in good time.

In this work, you, as an employee or partner, are a key factor. If you think something doesn’t feel quite right, it’s important to us that you can bring this up in a safe way. Therefore, we offer two different options for you to speak up – through internal reporting or by whistleblowing through an independent external party.

What can be reported?

If you feel that you need to raise an issue, this in itself is reason enough to report it. It is important for us as an organization to live up to our values. Therefore, we need help in receiving information about when this does not occur, so that we can clearly demonstrate the limits and values that apply.

An example of a problem that may be reported is when someone in our organization or a partner acts in violation of our code of conduct – what we as a company stand for, our values and how we do business. The incident may also be about more serious malpractice and outright illegality such as fraud, embezzlement, corruption, breach of trust, information theft, corporate espionage, and data breaches.

If our guidelines are not helping, you can receive guidance from the following questions to decide how you should act.

  • Have you seen a problem that goes against what we stand for and how we say we should work?
  • Do you consider what has happened to be legally or ethically defensible?
  • Would our business be harmed if the situation were made public?
  • How would you see the issue if you were a customer or another stakeholder?

1. Internal reporting
As soon as you experience irregularities or that something is wrong, you should either turn to your line manager or their manager. If you dare not trust any of these people, for example if you suspect that they are involved, you should initially raise the issue with someone in management.

Do you feel hesitant about taking the matter up with someone in senior management? Then you should take advantage of whistleblowing.

2. Whistleblowing
Depending on what you need to report, sometimes raising an issue internally is not the right course of action. So, we offer the option of whistleblowing. This is an important safety valve, both for us and for you as an employee. Exactly for this reason, we use an independent external party, Whitepaper Advisors. Through their Trumpet whistleblower system, you can report serious malpractice committed by someone in management or by another key person in the business anonymously and confidentially – see our whistleblower policy.

What can be reported?

Swedish law sets restrictions on what may be addressed by a whistleblower system. Therefore, things that do not constitute serious malpractice may not be reported via the whistleblower system, such as general dissatisfaction with how the business is conducted, leadership, salary, or other personnel matters. Neither may acts committed by people who are not in management or who are not key figures in the business be addressed by the whistleblower system.

A complaint through the Trumpet whistleblower system must be based on concrete suspicions. You do not have to have proof of your suspicions, but no accusation may be made with malicious intent or in the knowledge that the accusation is false. False or malicious accusations are a serious breach of your employment contract. Read more in our whistleblower policy.

Who can submit a report?

A whistleblowing complaint can be submitted by anyone representing the Company in any way. This includes board members, all employees (permanent employees, probationary staff, fixed-term employees, full-time and part-time employees), trainees and hired staff (recruited staff). Even employees of the Company’s suppliers, consultants and partners have this opportunity.

How case handling works

Trumpet is an external whistleblower service, providing you with a secure process where you can be completely anonymous as a whistleblower. If you do not put your name in the report yourself, it is not possible to see who has submitted the case to the system. Trumpet has been developed based on the highest standards of confidentiality and security.

Trumpet follows the EU GDPR directive and the EU directive for the protection of whistleblowers, as well as Swedish law relating to special protection against retaliation for employees who raise an alarm about serious misconduct.

Whitepaper Advisors is behind the system – a company with solid experience in investigating and helping organizations deal with malpractice. You can find more information at www.trumpet-whistleblowing.eu

The process step-by-step:

  1. By reporting through Trumpet, you can make sure that you are completely anonymous – no one knows who you are as the person making the report, unless you yourself choose to be open about your identity.
  2. When you report an incident in the system, an encrypted case is created in the whistleblower system to which you receive a unique encryption key.
  3. It is always an external independent case worker – at Whitepaper Advisors – who receives your case and makes the first assessment of your report. Only you and your case worker can access your case, each using your encryption key.
  4. To make the process simpler, you can make the active choice to be open about your identity with the independent case worker. This way, you and your administrator can have an effective and secure dialog – no one else will find out who you are. You also have the option of choosing to be open about your identity with the organization.
  5. After your case worker has made his/her assessment, a recommendation is submitted to our organization’s whistleblower committee. This committee in turn decides how the matter should be progressed and the measures to be taken. If anyone on our committee is involved in your report, they will be excluded by Whitepaper Advisors before the recommendation and report are submitted. You can see the members of the committee in our whistleblower policy.
  6. Whitepaper Advisors case workers will notify you of the status of the case and the committee’s decisions via the secure Trumpet login.

How to make a report

You can make a report to Trumpet via a web link, by telephone or by letter. Reports can be made 24 hours a day, 7 days a week and may be submitted in Swedish and English. A report through Trumpet is always handled with anonymity and with the utmost confidentiality. If you wish to prevent anyone having the opportunity to track your activity, you should use a private computer or mobile phone and visit the service from a network you trust, such as your home network.

  • A report can be made via the Trumpet website by entering the address www.trumpet-whistleblowing.eu on any device (computer, tablet, or mobile phone) and then entering our organization code below to log in to the whistleblower page.
  • Reporting by telephone involves slightly different handling than through the website. Read more on the Trumpet website about what applies to each reporting method.

Trumpet whistleblowing:
www.trumpet-whistleblowing.eu

Use our organization code:
imunowb

On the Trumpet website there is a clear guide through the whole process. You can find answers to frequently asked questions at every stage.