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Whistleblower policy

1. Our approach 
Falck encourages employees to raise concerns about irregularities or improper actions that have been committed, are suspected or likely to be committed, or actions that fail to comply with applicable laws and regulations, the Falck Code of Conduct or internal policies. Falck’s integrity is non-negotiable as the company is committed to conducting business in accordance with the law and Falck’s ethical principles. Falck provides a platform for employees to raise serious and sensitive concerns and ensure that such concerns are treated appropriately. Whether the report is made anonymously or not, Falck reassures reporters raising such concern that they will be protected from reprisals or retaliation. Any form of threat, retaliation or discrimination towards a reporter will not be tolerated and will be treated as a disciplinary matter. By speaking up, you are giving Falck the opportunity to deal with the concern. Remaining silent about possible misconduct may worsen a situation and decrease trust. 
2. Scope 
The Whistleblower Policy (“the Policy”) applies to everyone in the Falck Group and complements the global Falck Code of Conduct. The Policy covers the reporting of any actual, suspected or potential misconduct in relation to Falck’s ethical principles, the Falck Code of Conduct, internal policies or applicable laws and regulations. 
Falck will adhere to all applicable laws and regulations, and where such laws impose higher standards than the Falck Code of Conduct or supporting policies, the higher standard must be followed.  
2.1 Whistleblower system 
Falck Alert is available to all employees to make a report in good faith on any concern or knowledge of improper actions. The system is a global Whistleblower system which can be used in 5 different languages; namely English, Danish, German, Portuguese, Spanish and is available online or via Falk Alert App. 
You are encouraged to provide as much detailed and specific information as possible as this will help the investigation and give Global Audit & Compliance an opportunity to address the full scope of your issue in a timely manner. When necessary, a report can be made anonymously if you do not feel comfortable providing your contact details.  
Global Audit & Compliance provides reassurance that your data and the information you provide are protected whether the report is made anonymously or not. If you file a report anonymously, it is essential that the option Secure Post Box (secured communication channel in Falck Alert) is selected (by default) in the reporting form as this allows Global Audit & Compliance to communicate with you while you remain anonymous. If you choose to deselect the option Secure Post Box while choosing to remain anonymous, Global Audit & Compliance will only have access to the information you filed in your report and will not be able to get further information from you.  
2.2 Nature of the reports 
The purpose of Falck’s Whistleblower system is to protect the integrity of the business, and employees are therefore encouraged to speak up where something seems like what it should not be. Reports made could relate to, among others: 
• Activities, which otherwise by law, treaty or agreement amount to serious improper conduct (e.g. discriminatory practices, sexual harassment, use of child labour, human rights violations) 
• Financial fraud (e.g. accounting manipulation, non-compliance with internal controls procedures, misappropriation of assets or fraudulent statements); 
• Bribery or corruption (e.g. conflicts of interest, bribery, sponsorships & donations, gifts or facilitation payments); 
• Violation of competition laws (e.g. price fixing, exchange of price sensitive information, collusion with competitors); 
• Serious endangerment to environment, health and safety; 
• Any acts by senior management that cannot be reported using local channels; 
• Other unlawful activity. 
What should not be reported via Falck Alert? 
• Ordinary employment matters related to complaints, e.g. wages, holiday time, employment or union contract matters; 
• Complaints concerning practical matters, e.g. problems with a PC, food quality, heating/cooling in an office; 
• Strictly ‘local’ complaints, e.g. “My boss does not appreciate my ability and did not promote me”, “My colleagues do not treat me politely”; 
• Violations of internal policies on routine matters, e.g. dress codes, smoking, alcohol, vacation, sick leave. 
In these cases, the normal communication channels must be used instead, such as the direct manager or local HR. 
2.3 Data protection 
As reports made in Falck Alert will usually contain personal data, Falck has an obligation to protect this data. Falck has chosen an external supplier to manage the Whistleblower system who is required to make sure that adequate security measures are in place and in accordance with applicable data protection law.  
All data will be processed with a high level of security and deleted when no longer needed to facilitate investigation or as evidence. If the case leads to disciplinary sanctions or if it is otherwise necessary and objectively reasonable to keep the information, the information will be kept in the employee case file. The information will then be kept up to 5 years or in accordance with applicable data privacy laws. 
3. Responsibilities  
3.1 Raising concerns 
Falck’s intention and main priority with this Policy is that your concerns are heard, and that there is accountability or action taken on unethical or illegal conduct. You can therefore raise your concern directly with your manager, local or Global HR, or any other channels you feel comfortable using.  
If you do not feel comfortable raising the concern directly to your manager or other internal channels, you can make a report via Falck Alert as per this Policy. 
3.2 Receipt and retention of concerns and investigation 
Reports through Falck Alert can either be made online via website (FalckAlert.com), or through the Falck Alert App where you will be able to make the report in your preferred language. 
When reporting online, you fill out a form via an independent third-party supplier. The data you submit is only visible to the investigators with access rights. First screening of the reported issue is followed by making a collective decision by Global Audit & Compliance on assigning the investigator who will be responsible for handling your issue. Global Audit & Compliance is responsible for initiating investigations and must approve the scope, evaluation and conclusions of all investigations. Global Audit & Compliance is also responsible for overseeing that all relevant documents are archived.  
Based on the notification and other relevant information from the report, the investigator assigned to your case will decide how to proceed. The next step can be a request for further information, a hearing, a report to the police, employment consequences and/or notification to the relevant employee. In case a further investigation is carried out, it could involve further parties who will be appropriately assigned with investigating the case. 
The character of the investigation may justify the use of external assistance e.g. from lawyers, auditors or consultants. If the case involves a member from Falck Board of Directors or Falck Executive Management, then external assistance is required in the investigation. 
The conclusions of an investigation may be submitted to the Audit Committee. The Audit Committee may then decide on placing any investigation report before the Board of Directors depending on the gravity and magnitude of the violation. 
3.3 Remedial actions 
While reports can be made anonymously, Falck recommends that you identify yourself as this will ease further investigations. All reports are handled under conditions of strict confidentiality whether made anonymously or not. There will be no adverse consequences for anyone making a report in good faith. However, a reporter found responsible for making allegations in bad faith or maliciously may be subjected to disciplinary action.  
It is a violation of the Falck Code of Conduct to knowingly make a false accusation, lie to investigators, interfere with an investigation or refuse to cooperate in an investigation. Doing so may lead to disciplinary measures. 
The following actions may be taken after investigation depending on the concern: 
• Disciplinary action (up to and including dismissal) against the wrongdoer depending on the results of the investigation; or 
• Disciplinary action (up to and including dismissal) against the reporter if the claim is found to be malicious or in bad faith; or 
• No action if the allegation proves unfounded. 
You will be kept informed of the progress and outcome of the investigation, within the constraints of maintaining confidentiality or observing legal restrictions. A confidential record of the steps taken will be kept and this will be in accordance with relevant data protection regulations. 
3.4 Compliance with this policy 
Employees are responsible for ensuring that they comply with this Policy which includes always acting in Falck’s best interest by speaking up in case of any misconduct. 
Failing to comply will have severe consequences for the parties concerned up to and including dismissal and could be damaging to Falck’s activities and reputation. 
The current version may be amended from time to time and all employees must ensure they are compliant with the latest version of the Policy. If in doubt about anything relating to this Policy, including the applicable version thereof, please consult Global Audit & Compliance.