Whistleblowing Policy for Hagmans Nordic AB

The following policy applies to Hagmans Nordic AB. Whistleblowing refers to reporting, in a work-related context, information about misconduct that is of public interest to be disclosed. When Limhamnshus Industri handles matters relating to whistleblowing, this shall in all cases be carried out in accordance with applicable laws and regulations at any given time, in a secure and appropriate manner, and with respect for the special protection afforded to whistleblowers. The reporting channels provided for whistleblowing shall enable smooth, simple, and secure reporting of misconduct. In all cases of whistleblowing, Limhamnshus Industri shall ensure that whistleblowers are protected through appropriate security measures.

Purpose

The purpose of this policy is to provide a basis for establishing and ensuring an effective whistleblowing function. Through such a function, errors and deficiencies in the business can be detected, and thereby risks to both the business and individuals can be prevented. The whistleblowing function can also strengthen confidence in the business among employees and customers and contribute to a better working environment.

This policy will therefore:

• Describe the protection that shall be provided for whistleblowers, and how Hagmans Nordic ensures that this is maintained.
• Describe Hagmans Nordic’s reporting channels for whistleblowing, as well as how follow-up of such reporting shall be carried out.

Definitions

Whistleblowing refers to reporting, in a work-related context, information about misconduct that is of public interest to be disclosed.

Reporting

Oral or written submission of information about misconduct through internal reporting, external reporting, or public disclosure.

Work-Related Context

The reporting person has obtained or acquired information about misconduct in a work-related context and belongs to the group of persons covered by protection. This group includes, among others, employees, trainees, volunteers, shareholders, and persons who are part of a company’s administrative, management, or supervisory bodies. The protection applies before a work-related context has arisen, during its duration, and after it has ended. 

Misconduct

The misconduct covered includes both actions and omissions, regardless of whether it concerns intentional or negligent behavior or whether the misconduct is due to accidental events. An attempt to conceal misconduct may in itself constitute an action covered by whistleblower protection.

Public Interest

For there to be considered a public interest in the disclosure of misconduct, the misconduct must concern the public. This generally does not apply to reporting matters that only concern the reporting person’s own working or employment conditions. However, there may be a public interest in such matters in special cases, for example if the person works under slave-like conditions or if an employer systematically violates applicable regulations. It may also be the case that misconduct concerning an individual agreement affects the public even though it technically only concerns the contracting parties, for example in cases of corruption. It is also required that the public’s interest in the disclosure of the misconduct is legitimate. General curiosity is not such an interest.

Protection for Whistleblowers

Hagmans Nordic shall ensure that there is strong and clear protection for whistleblowers, in accordance with applicable law. Protection for reporting persons may apply to a person who belongs to one or more of the following categories:

• Employees

• Persons who make inquiries about or apply for employment with Hagmans Nordic

• Persons who apply for or perform volunteer work with Hagmans Nordic

• Persons who apply for or complete internships with Hagmans Nordic

• Persons who are otherwise available to perform or perform work under Hagmans Nordic’s control and management

• Self-employed persons who apply for or perform assignments for Hagmans Nordic,

• Persons who are available to become or are part of Hagmans Nordic’s administrative, management, or supervisory bodies

• Shareholders who are available to be or are active in Hagmans Nordic, and persons who have belonged to any of the above categories and have obtained or acquired the information during their time in the business.

Conditions for Being Covered by Protection

A number of conditions must always be met for a reporting person to be covered by whistleblower protection:

1. The misconduct must have occurred, or be highly likely to occur, in an activity in which the reporting person is, has been, or may become active, or is or has been in contact with through their work.

2, The reporting person must have reasonable grounds to believe that the information is true at the time of reporting.

3. The reporting is made internally, to an external authority, or through public disclosure, in accordance with the procedures and manner prescribed by law.

A person who, in obtaining the information, commits a criminal offense is not covered by the protection.

Protection in the Form of Freedom from Liability

Hagmans Nordic may not impose any form of liability on a reporting person, provided that the person, at the time of reporting, had reasonable grounds to believe that reporting the information was necessary to reveal the reported misconduct. Freedom from liability does not entail the right to disclose documents.

Protection Against Obstructive Measures and Retaliation

Hagmans Nordic may not attempt to prevent reporting or, as a result of reporting, take retaliatory measures against the reporting person, persons assisting the reporting person in the reporting, persons connected to the reporting person, or legal entities that the reporting person owns, works for, or is otherwise work-relatedly connected to.

Hagmans Nordic may also not take retaliatory measures because someone turns to their employee organization for consultation regarding reporting. Limhamnshus Industri may not prevent or attempt to prevent such consultation.

Reporting

Hagmans Nordic shall have internal reporting channels and procedures for reporting and follow-up. This includes appointing independent and autonomous persons/units authorized to, on behalf of Limhamnshus Industri, receive reports and maintain contact with reporting persons, follow up on what is reported, and provide feedback on the follow-up to reporting persons. A person handling a follow-up case is bound by confidentiality and may not improperly disclose information that can reveal the identity of the reporting person or any other individual involved in the case.

Those appointed may either be employed by the operator or by an external party engaged to manage the reporting channels and procedures on behalf of the operator. Independence means that the person shall have a certain mandate to act without the operator’s approval, particularly when it comes to initiating and concluding investigations, and the freedom to formulate conclusions from the follow-up of reports without the operator approving those conclusions. The operator should not be able to penalize a person who has been appointed as authorized because they perform their duties as an authorized person. Authorized persons should, if possible, not report according to the ordinary hierarchy but directly to a higher level.

Reporting Channels

HHagmans Nordic shall provide internal reporting channels and ensure that there is an opportunity to report anonymously. Limhamnshus Industri shall provide clear and easily accessible information on how reporting is carried out and how it is handled. Such information shall also be provided regarding how reporting is made through external reporting channels, regarding freedom of expression and acquisition, as well as the prohibition of retaliation. The internal reporting channels shall be available to:

1. employees
2, volunteers
3. trainees
4. Persons who otherwise perform work under Hagmans Nordic’s control and management
5. Self-employed persons who perform assignments for Hagmans Nordic
6. Persons who are part of Hagmans Nordic’s administrative, management, or supervisory bodies, and shareholders who are active in Hagmans Nordic.

Through such reporting channels, these persons shall be able to report misconduct occurring within Hagmans Nordic. The reporting person shall be able to submit a report in writing, orally, or by requesting a physical meeting, which shall then be scheduled.

Follow-Up

Hagmans Nordic shall provide the reporting person with confirmation of receipt of the report within seven (7) days, unless the reporting person has waived such confirmation. The reporting person shall also receive feedback on the measures taken in response to the report, and the reasons for these, within three (3) months from the confirmation. If information that can identify the reporting person is to be disclosed, the person shall be informed of this.

Documentation and Processing of Personal Data

HHagmans Nordic shall document its internal reporting channels and procedures in writing. The entire function shall be described: which reporting channels exist, how reports are received, how confirmation of receipt is provided, how reports are documented, how the reported matters are investigated, and how both anonymous and non-anonymous reporting persons receive feedback.

Upon receiving an oral report, Hagmans Nordic shall document it either through a recording that can be stored or through written minutes. Recording requires the consent of the reporting person. The reporting person shall be given the opportunity to review, correct, and approve a recording or minutes by signature.

Hagmans Nordic shall retain written reports and documentation of oral reports for as long as necessary, but never longer than two (2) years after a follow-up case has been closed.

Hagmans Nordic may only process personal data if such processing is necessary for a follow-up case. Other personal data may not be collected and shall be deleted as soon as possible if collected by mistake. Only persons who have been appointed as authorized or persons working in units designated as authorized to receive, follow up, and provide feedback on reports may have access to personal data processed in a follow-up case. Access to personal data shall be limited to what each person needs in order to perform their duties. Personal data in a follow-up case may not be processed longer than two (2) years after the case has been closed.

Supervision

Hagmans Nordic shall, upon request by a supervisory authority, provide the information and documents necessary for supervision.