Elkapsling AB Whistleblower Policy
Elkapsling AB strives to maintain high standards of ethics and integrity. This whistleblower policy aims to create an environment where employees, suppliers and other stakeholders can report any irregularities or misconduct without fear of retaliation.

The purpose of whistleblowing is to facilitate the reporting of serious irregularities. Employees should feel safe and know that they can report irregularities and serious incidents affecting the company without fear of negative consequences.

Who can report
A report of whistleblowing can be submitted by anyone who in any way represents or is active in the company in work-related contexts. This includes all employees, trainees, jobseekers, consultants and agency workers. Members of the board of directors and shareholders can also submit a notification, as well as persons who are members of the company’s supervisory board, such as auditors.
What can be reported via the whistleblower function?

The whistleblowing service will be used to warn of serious risks of irregularities that may affect people, our organisation, society or the environment. Cases reported may include information on criminality, irregularities and infringements or other acts that violate EU or national law in a work-related context, such as:

• Corruption and financial irregularities, such as bribery, unfair competition, money laundering, fraud and conflicts of interest
• Crimes related to health and safety, such as health and safety, serious discrimination and harassment that is against the law
• Environmental crimes, such as illegal handling of hazardous waste
• Violations of privacy, such as misuse of personal data

As a whistleblower, you do not need to have proof of your suspicion, but you must have reasonable grounds to believe that the information you provide is true. As a starting point, you should have first-hand information as reports that are made solely on the basis of rumours or hearsay are not covered by the protection. No accusation may be made with malicious intent or with the knowledge that the accusation is false.
False or malicious accusations are a serious breach of the employment contract, and there is no retaliation protection in case of false or malicious reports.

The whistleblower does not risk incurring any consequences from the reporting, either at the time of reporting or afterwards.
We ask employees to raise issues such as dissatisfaction in the workplace or complaints about their own personal circumstances with their immediate manager, superior manager or HR, as these issues cannot be treated as whistleblower cases.
If you are unsure whether what you want to raise falls within the scope of this policy, we advise you to consult with your immediate manager or HR.

How is a report made?
In the first instance, as an employee, you should report directly to your manager, superior manager or HR, which you can do via email, phone or in person. If you feel that you cannot report to any of these, you can use our internal whistleblower function, follow this link:
[email protected]
It is also possible to call or book a meeting to raise the alarm, telephone number 0690-76 30 26. The following questions are asked when reporting:

• Who is involved?
•When? How? Where?
• Other information relevant
• Your name and contact details (optional)

You should always primarily report in accordance with our internal whistleblower function described above. If you do not receive a response or feel that the case has not been handled correctly, it is also possible to report via external reporting channels. Reporting is then made to the competent authority, such as the Swedish Tax Agency or the Swedish Work Environment Authority.

Reception and handling
All reports made in accordance with this whistleblower policy are taken seriously and they are handled professionally and confidentially.
Only the persons who have the authority to handle whistleblower cases have access to the reports received through the whistleblower function.
This limited circle includes the company’s HR manager.
If the notification relates to the above, an alternative group will be set up which does not include such a person concerned.

Feedback to the whistleblower must be based on the Swedish legal requirements that exist.

• Within 7 (seven) days, whistleblowers must receive feedback that the case has been received
• Within 3 (three) months, a conclusion is communicated to the whistleblower regarding the case

In order for feedback and dialogue to take place regarding the case, an e-mail address needs to be provided. Your e-mail address will not be shared at any time and your anonymity will not be affected by sharing your e-mail address. Its purpose is only to be able to notify you when Elkapsling AB has responded to your case.

The person responsible for the whistleblower function, HR, decides whether the case should be approved or rejected. Cases as follows will be rejected:

• The alleged conduct is not reportable under this policy
• The matter is malicious or has not been made in good faith
• The case has already been resolved

If the report is approved, appropriate investigative measures will be taken.

Whistleblower protection
The Whistleblower Act (Act 2021:890 on the Protection of Persons Who Report Misconduct) applies to the reporting in a work-related context of information about misconduct that there is a public interest in revealing or actions that violate EU or national legislation.

Click here to read more about the Whistleblower Act.

In the event of an investigation, the whistleblower needs to be prepared to answer any follow-up questions, thus full anonymity from the whistleblower unit cannot be guaranteed. If you wish to guarantee full anonymity, you have the right to refrain from filling in your contact details via the external whistleblowing reporting tool.

After a case is closed, no later than after two years in accordance with the provisions of the Whistleblower Act and GDPR, all personal data in the case is deleted.


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