Whistleblowing

Procedure for whistleblowing

At Bengt Dahlgren, we work for transparency in our business environment and therefore we follow a number of ethical guidelines, our code of conduct, in order to conduct both a sustainable and profitable business in relation to our employees and our customers. Our Code of Conduct serves as guidance for our own work and for assessing those with whom we intend to do business. We actively work for a business climate where everyone feels a sense of responsibility and security in reporting irregularities. If there are suspicions of fraudulent behavior, receiving or giving that can be perceived as bribes or other things that could damage our brand, this must be reported immediately.

Based on current legislation, with enhanced protection for reporting, Bengt Dahlgren's management undertakes, in connection with a report, to ensure freedom from liability and prohibition of so-called obstructive measures and reprisals, such as separation from employment, financial sanctions, relocation, discrimination, lost business opportunities and terminated contracts. Furthermore, this also applies to indirect reprisals that may, for example, affect a relative or family member who has a direct connection to the company. Furthermore, the reporting person may not be held responsible for reporting information that is subject to confidentiality, provided that the person is covered by protection. The new Whistleblower law covers the following categories of persons:

1. Employees and hired personnel, since before.
2. Job seekers
3. Self-employed
4. Volunteers and interns.
5. Persons who are part of a company's administrative, management or supervisory body.
6. Shareholders who are active in the company.

A prerequisite for protection is that the person is, has been, or may become active within BDAB group, but this also applies to a person from another business, provided that there has been a contact through work performed. Therefore, this document must be shared with all concerned based on the criteria mentioned above.

When a report is to be made, the person must have reasonable grounds to assume that information about the irregularity is true. Irregularities or misconduct can be defined as below with examples from the Whistleblowing law chapter 1 § 2.

• Irregularities onlcy where the crime has imprisonment in the penalty scale.
• Serious misconduct such as violations of fundamental rights, risk to life and health or damage to the environment.
• And there must be concrete suspicions. Further checks may need to be carried out if there are difficulties in investigation or verifying the accuracy of the data.

Pleas note that this legislation does not cover the reporting person’s own working or employment conditions, with the excetion of slav-like coditions or systematic violations of current regulations. Also it does not include classified information.

Procedure for reporting

Once an irregularity or misconduct of a serious nature is discovered, this will be reported on a voluntary basis, as follows:

Registration is done via e-mail or by phone at the number given below.

You can choose to remain anonymous, but if there is a police investigation, anonymity will be difficult. Note, however, the enhanced protection for the individual in the Whistleblower law. However, this will not apply if you, as the notifier, were involved yourself. Otherwise anonymity applies until otherwise agreed.

Contact details

Recipient of report is Chairman Petra Palmgren Lindwall petra.palmgrenlindwall@bengtdahlgren.se
+4673-414 28 00 
+46(0)31-792 28 00

The report must contain the following information, se template

1. Which company is the subject of the irregularity.
2. What type of irregularity has been observed
3. Who is the suspect

It is important that you provide as detailed information as possible so that the report can be handled safely and efficiently.

Who is the recipient?

Appointed member of BDI, according to above, is mainly responsible for receiving and distributing to the company concerned the matter. Recipient at the affected company is the Chief Financial Officer/financial manager and has a responsability to convene the top management within the own company for further investigation. If the matter affects someone from the top managemant the CFO excludes that person. If the matter affects the CEO the recipients must distribute the matter within Bengt Dahlgren Stakeholders (BDI).

GDPR

Only people who handle the follow-up of the case have access to personel data to the extent required. This information may be kept for as long as it is considered necessary, but for a maximum of two years after the case has been closed.

All persons involved in a case have a duty of confidentiality.