Skanem whistleblower channel
Skanem has established a Whistleblower Channel enabling employees and external parties to report concerns about possible illegal actions and breaches of Skanem’s Code of Conduct.
What can be reported?
Skanem encourages everyone to speak up and report issues of concern that may threaten the company’s finances, operations or reputation. This includes violations in areas such as health, security & environment, people and labor standards, financial integrity, confidentiality, conflict of interest, bribery and corruption and fair dealing.
You decide what information is to be reported. However, to ensure sufficient information and be able to perform adequate follow-up actions, the reports should include as much details as possible and, if available, supporting evidence.
How to report a concern
We strongly prefer direct communication, but respect that can be difficult. You may therefore use Skanem’s independent Whistleblower Channel managed by PricewaterhouseCoopers (PwC). PwC is committed to a high ethical standard and will handle all notifications confidentially.
You have three ways of using the Whistleblower Channel:
You may report anonymously, but when doing so you must be aware that the receiver cannot give feedback.
Proper investigation may prove difficult if the information provided cannot be tested or verified and the investigator is unable to obtain further information from the whistleblower.
the document How concerns are handled
Skanem’s basic principles for handling reports are:
- All reports are taken seriously
- Fair, open and objective follow-up
- Protection of anonymous whistleblowing
- Confidentiality and information security
- No whistleblowing will be subject to reprisals
- Non-anonymous whistleblowing will get timely feedback and information about the process
Below is a summary of the main steps in handling of whistleblower reports received. More details about the standard procedure, including guidance, are found in the chapter Whistleblower Routine in the document Skanem CSR Policies on the Skanem Intranet.
PwC will perform a preliminary evaluation and quality assurance of all notifications received through the Whistleblower Channel before delivering an initial report to CEO at Skanem HQ. If the report reveals conditions that require investigation, an investigation team will be appointed.
External advisors or internal resources may be used to conduct the investigation. The decision regarding who will conduct the investigation will be based upon the nature of the violation reported and the resources available to conduct the investigation.
The Whistleblower, unless chosen to remain anonymous, and the person who has been reported on shall as a minimum receive information that the case is considered and concluded, also in the case that no irregularities or issues of non-compliance are found in the investigation. Whistleblowers that are not parties to the case are in principle not entitled to any information about the execution of the investigation or to the conclusion in the summary report, and information provided will be decided on a case to case basis.
A summary report with the final results of the investigation will be completed within a reasonable time and will be reviewed by the CEO and/or external advisor as appropriate. The summary report shall be filed according to the internal archive routine and data protection acts.
Based on the outcome of such investigation, the CEO and/or Chairperson of the board of Skanem as appropriate shall take any such action and/or impose such sanctions as are deemed appropriate and/or necessary, including any preventative measures, disciplinary sanctions or termination of supplier contract etc. For employees, consequences may involve verbal or written warnings or, if the matter is very serious, termination of or summary dismissal from their employment.
Protection of whistleblowers
It is as important for Skanem to provide a mechanism to safely report illegal activities and/or serious misconduct, as it is for the company to protect and to avoid damage to the reputation of innocent employees or board members who are the subject of a reported violation.
For these reasons, Skanem will conduct its investigations of any reported violation as discreetly as possible and in a confidential manner to the greatest extent possible commensurate with carrying out a thorough and adequate investigation. Furthermore, to the extent possible, all reasonable efforts will be made to treat the whistleblower’s identity as confidential, unless permission in writing (including email) has been obtained from the whistleblower. The protection of identity shall also be taken into consideration during the initial evaluation and the subsequent risk assessment when scoping the investigation, hereunder the existing level of risk exposure without disclosing the name of the whistleblower. All investigations will be conducted in a confidential manner, so that information will be disclosed only as needed to facilitate review of the investigation or otherwise as required by law.
Skanem prohibits any retaliation against whistleblowers and will provide adequate measures to prevent retaliation within the organization. Retaliation is in itself a breach of the company’s policy and any such acts may lead to appropriate sanctions as described above. Retaliation is any negative action, practice or neglect as a consequence of or reaction to the whistleblow, e.g. victimization, threats, harassment, discrimination, social exclusion, warnings, deprivation of work tasks, groundless relocation, degradation, poor wage development, suspension, dismissal, summary dismissal and/or disciplinary punishment.
Anyone who experiences retaliation must report this according to this policy.
Skanem will take appropriate disciplinary or legal action against any person who is found to have made a disclosure maliciously that they know to be untrue, or without reasonable grounds for believing that the information supplied was accurate.
Handling of reports of concerns will be done in accordance with the Norwegian Personal Data Act and Regulations on the Processing of Personal Data.