Gibotech has established a whist­le­blower scheme, providing you as a supplier, customer, or partner with the opportunity to report actual or potential viola­tions that have occurred, are occurring, or are likely to occur at Gibotech.

The purpose of the scheme is to ensure that you can report these matters without fear of threats, reprisals, or other negative consequences. When you use the whist­le­blower scheme, you are therefore guaranteed protection.

Anyone wishing to report matters at Gibotech can use the whist­le­blower scheme.

How to report

You report via Gibotech’s whist­le­blower scheme.

When you make a report, you have the option to create a so-called “Secure Mailbox.” You can use the mailbox to send addi­tional docu­men­tation related to your report. The mailbox can also be used if the whist­le­blower committee needs to contact you.

All commu­ni­cation through the secure mailbox is anonymous.

When you create a secure mailbox, it is important to remember to save the link gene­rated for you. It is not possible to recover the link afterwards.

You can also choose to report via the Data Protection Agency’s whist­le­blower scheme, so the report initially reaches a neutral party.

What can be reported?

You can report the following under the whist­le­blower scheme:

• criminal offenses, such as fraud, embezzlement, misuse of assets, acco­unting mani­pu­lation, bribery, corruption, money laun­dering, and financing of terrorism,
• document forgery, hacking, data fraud, inter­ception and recording of conver­sa­tions between others,
• breaches of compe­tition and procu­rement rules,
• all forms of extortion,
• serious or repeated breaches of labor laws,
• serious breaches of environ­mental rules and environ­mental pollution,
• serious or repeated breaches of signi­ficant internal policies and guide­lines at Gibotech,
• serious work­place conflicts; for example, severe bullying, haras­sment, discri­mi­nation, physical violence, threats, and sexual harassment,
• severe haras­sment, for example, based on race, gender, color, language, financial status, national or social origin, or poli­tical or reli­gious affiliation.

What cannot be reported?

The whist­le­blower scheme is a supplement to the normal dialogue between employee and manager or Gibotech and external parties.

Therefore, you cannot report the following via the whist­le­blower scheme:

• personal grie­vances including; salary issues, diffi­culties in coope­ration, viola­tions of smoking or alcohol policies, sick leave, etc.,
• other matters, including HR issues, minor viola­tions of Gibotech’s internal guide­lines, complaints about other employees’ behavior or lack of skills; including infor­mation about less serious conflicts and disa­gre­e­ments in the workplace.

The whist­le­blower committee may reject reports that are not covered by the law’s scope, and is not obliged to forward them to another authority.

Handling of reports

Your report is received by Gibotech’s HR Coordinator, who either inve­sti­gates the content further or decides that it should be rejected or shelved.

If the report falls under the whist­le­blower scheme, it must be handled by the whist­le­blower committee. The committee conducts an inve­sti­gation of the report and the case in general.

If the report concerns one or more of the indi­vi­duals from the whist­le­blower committee, they will be excluded from the inve­sti­gation, and others will take their place.

As a reporter, you will receive confir­mation within seven days of receipt of your report. You will gene­rally receive feedback within three months, but in special cases, it may be necessary to extend the deadline to six months.

Processing of personal data

The personal data handled in connection with the whist­le­blower scheme’s reporting portal is stored only for the period necessary to inve­stigate the report and take appro­p­riate action unless there is another legal basis for longer data retention.

Personal data is deleted after the completion of the initial inve­sti­gation if it turns out that the report is unfounded.

If a formal inve­sti­gation is launched based on a report, personal data is deleted within two months after the conclusion of the inve­sti­gation. Justified reports containing infor­mation that may lead to employment, civil, or criminal liability are kept until the conclusion of the respective processes/legal actions in accor­dance with the requi­re­ments of the appli­cable law.

Processing of personal data related to whist­le­blower reports, where EU Regulation 2016/679 (“GDPR”) applies directly, must comply with all GDPR guide­lines, including adequate infor­mation to all affected indi­vi­duals about data processing, infor­mation about the relevant legal basis, storage of personal data for a specific period, and respect for data rights as set out in the GDPR.

Reference is also made to Gibotech’s general privacy policy.

Do you have any questions?

If you have any questions regarding Gibotech’s whist­le­blower scheme, you can contact our HR Coordinator at hr@​gibotech.​dk.