Patrade A/S, company reg. (CVR) no. 38740571
INTRODUCTION AND PURPOSE
The purpose of the whistleblower policy is to explain how the whistleblower scheme works and thereby create a preventive effect and counteract any potential reluctance to report serious concerns.
Patrade’s whistleblower scheme is intended, among other things, to improve the opportunity for employees, business partners and others to point out and make representations about illegal or serious misconduct in a safe and secure manner without having to fear that doing so may have adverse consequences for them.
Patrade first and foremost intends for problematic conduct to be addressed directly in a free and open dialogue with the immediate superior or other relevant employee. However, if specific conduct is not suited to be discussed in such a forum, a concern may instead be reported confidentially or anonymously through Patrade’s whistleblower scheme.
WHO CAN REPORT CONCERNS?
Concerns may be reported by all employees of Patrade as well as by other persons affiliated with Patrade, such as business partners, customers, suppliers, external advisers and board members as well as candidates attending job interviews etc.
WHAT AND WHO CAN BE THE SUBJECT OF REPORTED CONERNS?
Concerns may be reported about any type of illegal or serious misconduct. Concerns may also be reported in the event of suspected illegal or serious misconduct. Examples of serious misconduct may be financial/economic crime, corruption, accounting irregularities, physical or psychological abuse, sexual abuse or other inappropriate behaviour, serious violation of occupational health and safety standards or environmental regulations. Serious violations of internal policies are also covered by the whistleblower scheme.
Concerns may be reported about misconduct committed by Patrade employees or misconduct involving a Patrade employee or a person who is otherwise closely affiliated with Patrade.
The whistleblower scheme cannot be used for reporting minor or less serious matters such as dissatisfaction with salary conditions, collegial difficulties or less serious violations of internal policies etc.
In case of doubt, Patrade would recommend reporting the matter rather than not reporting it. All reports will be registered, dealt with and taken seriously.
HOW TO REPORT A CONCERN
Concerns may be reported using this link.
REPORTING A CONCERN
Reports may be made in writing or orally, but only using the above link. Concerns cannot be reported in any other way, as they involve confidential personal data which may not be transmitted in unencrypted form.
When reporting a concern, a request may be made to raise the matter at a meeting held in person. In such cases, the report cannot be made anonymously, as contact information on the person reporting the concern is required in order to set a date for a meeting in person within a reasonable time.
WHO WILL DEAL WITH REPORTED CONCERNS?
Reports will be dealt with by the person appointed by Patrade to be in charge of the whistleblower scheme, Attorney Christoffer Lindhardt Larsen.
The person responsible for the whistleblower scheme will inform management about reported concerns, unless the concern involves management, in which case the Chairman or the Deputy Chairman of the Board of Directors will be informed about the reported concern.
HOW ARE REPORTED CONCERNS DEALT WITH?
Reports of concerns will be processed within seven days of being reported. When a concern is reported, it will be registered and an initial investigation into the matter will be conducted.
If the person in charge of the whistleblower scheme finds that the matter falls within the scope of the whistleblower scheme, the concern will be investigated further.
If the person in charge of the whistleblower scheme finds that the matter is clearly unfounded or that the matter does not fall within the scope of the whistleblower scheme, the concern will be rejected and deleted. If possible, the person who reported the concern will be informed to that effect.
A case will be deleted in the system when the case processing has been completed, either because the matter has been resolved or because the concern could not be processed. Information provided in connection with a report and obtained in connection with the investigation of concerns will be stored, processed and erased in accordance with applicable data protection legislation.
If required in order to prevent breaches of the law or other serious matters, information may be disclosed to the police or other public authority. To the extent possible, and having regard to the case processing in general, the person reporting a concern will be informed about such disclosure.
WHAT HAPPENS AFTER A CONCERN HAS BEEN REPORTED?
After a concern has been reported, the person who made the report can log onto the IT system anonymously to be updated on the case processing. The case worker may have asked additional questions or requested additional evidence etc. Any communication through the IT system will be completely anonymous, and the person reporting the concern cannot be required to participate in any further communication or case processing. However, choosing not to participate may hamper efforts to elucidate the misconduct reported.
CONFIDENTIALITY AND ANONYMITY
Any person reporting a concern may choose to do so anonymously or confidentially. All concerns not reported anonymously will be treated confidentially to the extent possible. If you want to remain anonymous, you must choose a form of reporting which will ensure that your identity is not disclosed. You must also ensure that the report and any materials attached to the report form do not contain information that can be traced back to you.
All concerns reported with good reason are protected against reprisal of any kind.
If you report a concern in bad faith, it may have adverse consequences for you, including for your employment relationship.
The IT system used to receive and register reports is operated by Whistleblower Software ApS. Whistleblower Software ApS is an independent third party that guarantees the security and anonymity of the software provided.
The IT system does not log the IP address or information about the medium used to make the report. All data transmission and storage takes place in encrypted form. Only the person appointed by Patrade to be in charge of the whistleblower scheme has access to the reports in the system.
NOTIFICATION OF THE PERSON(S) REPORTED
Patrade is under an obligation to notify the person(s) about whom a concern has been reported. Prior to any notification, a specific assessment is made of what information may be disclosed and when, in order to ensure that notifying the persons involved will not have any impact on the elucidation of the matters reported.
The person(s) about whom a concern has been reported will not be informed about the identity of the person making the report. Not even if the identity of the person making the report appears from the report. In connection with a trial, it may become relevant to call the person making the report as a witness if that person’s identity is known.
If you have any questions relating to Patrade’s whistleblower policy, including to the whistleblower scheme, reporting procedures or any other matters, please contact Attorney Christoffer Lindhardt Larsen at Patrade on tel. +45 4022 5328 or by e-mail to email@example.com.
Enquiries about and questions relating to the whistleblower scheme will of course be treated confidentially.
Adopted by Patrade on 1 July 2021.