Whistleblower policy

Purpose

This Whistleblower policy is valid for all reports made through Vestas aircoil A/S’s Whistleblower Scheme.

The purpose of our Whistleblower Scheme is to give all our employees the opportunity to anonymously or not report on serious or criticisable conditions or events without the fear of retaliation or repercussions. Furthermore, the purpose is to secure the protection of the whistleblower who reports on mistakes or negligence which can lead to economical loss or harm Vestas aircoil A/S.

As an employee you are often the first to discover irregularities or illegal conditions in the workplace. Therefore, we at Vestas aircoil A/S have established this Whistleblower Scheme, to provide a safe space for making such report. Identifying such events or action and handling them in a fitting manner is at the utmost importance for us.

How can you make reports?

Reports can be made through our Whistleblower Scheme on this website. I’s not possible to make reports in any other way. Link: https://whistleblower.gapsolutions.dk/whistleblower/vestas-aircoil

Who can use our Whistleblower Scheme?

Our Whistleblower Scheme is available to all of our current employees including full- and parttime employees, substitutes, and fixed-term employees.

Which type of breaches can be reported?

Breaches falling within the material scope of the Whistleblower Scheme are:

1) Serious offences to national legislation or other serious conditions or event in the workplace. What constitutes serious offence depends on the specific assessment of the breach in question, but I can be breaches as:

Bribery
Document forgery
Hacking, recording conversations or wiretapping
Theft
Embezzlement
Fraud
Data fraud
Blackmailing
Sexual harassment
Gross harassment e.g. on the bases of race, gender, sexuality, skin color, language, national or social origin, political or religious affiliation

2) Breaches of the EU regulations as defined in article 2.1 in the whistleblower directive which can be found here. Link: https://eur-lex.europa.eu/legal-content/DA/TXT/HTML/?uri=CELEX:32019L1937

What cannot be reported?

The Whistleblower Scheme is a supplement to the normal daily dialogue between employees and management. Therefore, dissatisfactions with things like salary, cooperation difficulties, breach of smoking- or alcohol policies, sick leaves or other personal dissatisfactions cannot be reported through the Whistleblower Scheme.

It’s important that the Whistleblower Scheme is not abused to make accusations against innocent persons. All reports must therefore be done in good faith. If a report is made in bad faith, and is done in a rash of negative personal feelings, vengeance etc. it can result in warnings or termination of the employment etc.

Confidentiality and anonymity

All information or data received through our whistleblower solution is processed confidentially. Our whistleblower system is implemented in such a way that the confidentiality of both the whistleblower and the person who is subject to the report is secure. This includes that receipt, registration, and storing of the reports are only available to relevant personnel who are investigating the reports.

If you choose to report non-anonymously, we ensure the same level of confidentiality. However, if the report leads to legal processing or lawsuit against the person or persons who is subject to the report you may be called in as a witness. In such cases we cannot ensure your confidentiality.

Furthermore, there can occur situations where the identity of relevant persons may be revealed to relevant parties. This can e.g., be:

A police investigation is being pursued
The investigation leads to a court case being filed
The person making the report is offered special accommodation during the process, such as a leave of absence

Secure postbox

When making a report as a whistleblower, you have the opportunity to create a secure postbox. The postbox can be used to provide further documentation related to the initial report. The internal investigators and whistleblower can communicate through the secure postbox without the whistleblower’s identity being compromised. The use hereof is solely based on the whistleblower’s willingness to log-on and answer questions or upload further documentation.

If you choose to create a secure postbox, when making a report, you will create a password and be provided with a unique link to your postbox linked to the report. It’s very important that you save this link on your device, as the link cannot be reproduced.

Process for the handling of reports

Reports are initially sent to our partner GapSolutions A/S. They make an initial screening of the report to ensure that there is no conflict of interest between the content of the reports and the internal investigators.

Subsequent the report the released to HR Partner Esther Weirum Schmidt and Chairman Ib Sand Nykjær. The Whistleblower Unit or relevant persons in the units will then analyze the report to ensure that the content falls within the material scope of the Whistleblower Scheme. Hereafter they will conclude when the content of the report merits a further investigation or whether it will be rejected.

If the report concerns one of the persons in the Whistleblower Unit, then the report will be released to the other person in the Whistleblower Unit, who will conduct the same analysis.

If the report concerns both of the persons in the Whistleblower Unit, then the report will be released to the Group CFO Anders Lindenborg, who will conduct the same analysis.

If the report does not fall within the material scope, then the Whistleblower Unit can advise the whistleblower on how they should proceed with their report.

If the report falls within the material scope, then the Whistleblower Unit will conduct an internal investigation of the content.

The whistleblower will receive feedback on their report within 3 months after the report has been made to us. There can however occur circumstance where the whistleblower unit extends this deadline to 6 months. The Whistleblower Unit will inform the whistleblower of the extension and reasons within the initial period of 3 months.

If the report is sufficiently substantiated and the internal investigation finds it necessary, then appropriate measures will be applied to the person in question. This can be disciplinary sanctions, warnings, termination, police reports or in some cases lawsuit.

Whistleblower protection

When an employee in good faith reports under the scope of the Whistleblower Scheme, they are granted protection.

As a whistleblower you cannot be held responsible for the following:

Disclosure of confidential information, if the whistleblower is in good faith of the necessity of the information to uncover breaches of the law or serious conditions or event.
Procurement of information, unless the procurement is a result of a criminal offence such as hacking, wiretapping etc.
Breaches of contractual non-disclosure agreement with the company

Furthermore, a whistleblower is protected against retaliation and attempts of retaliation as a result of the reports.

This includes but is no limited to:

Termination, suspension
Changes in assignment, position, working hours, salary
Degradation or lack of promotions
Negative performance review
Harassment of any form
Exclusion of employee activities
Revocation of licenses or permissions
Other harmful action against the whistleblower or persons closest to the whistleblower

We take all claims of retaliations very seriously, and they will be investigated.

IT Security

Our whistleblower solution is hosted by GapSolutions A/S who is ISO 27001 and ISAE3000 certified and ensures the necessary security and anonymity in the solution.

GapSolutions A/S has taken the necessary technical and organizational measures to ensure that personal data is not a subject to accidental or unlawful destruction, is lost or compromised and that no unauthorized personnel is given access or can misuse personal data.

All data transmissions and storage of data are encrypted.

If a report is made from a device on the company’s network, there is risk that visited websites is logged in your browser history and/or in the company’s own logs. This risk can be eliminated by making your report on a device which is not connected to the company’s network.

If you upload document, you should pay attention to whether or not these contains metadata or other information that can compromise your on identify.

Logging

Registration of reports is done anonymously in the system. The only thing which is registered is the report itself. There is no log of the used IP-address or machine-ID on the device used to make the report.

Processing of personal data

Our processing of personal data regarding the whistleblower scheme is described in over privacy policy for the Whistleblower Scheme.

Questions

If you have questions, you are welcome to contact us at ews@vestas-aircoil.com.