WHISTLEBLOWER POLICY
The purpose of this Whistleblower Policy is to explain the functionalities of the Whistleblower Scheme, thereby avoiding any potential restraint on reporting subject-matters of material importance.
The Whistleblower Policy applies to reports made under the Euro Cater Group’s Whistleblower Scheme (“Whistleblower Scheme”) and applies to all affiliated companies within the Euro Cater Group, including Euro Cater, Dansk Cater and any of its subsidiaries as well as Svensk Cater and any of its subsidiaries (hereinafter “EURO CATER GROUP”).
A whistleblower scheme is a secure and anonymous option for employees or other interested parties attached to EURO CATER GROUP so that they can speak out if they are experiencing or suspecting anything illegal in EURO CATER GROUP or in any activities connected with EURO CATER GROUP, which may inflict a financial loss on EURO CATER GROUP or damage EURO CATER GROUP’s reputation.
EURO CATER GROUP is a responsible organization with an open-minded culture, where everyone is free to speak, also if they come across anything irregular or illegal.
The Whistleblower Scheme is a supplement to the direct and everyday communication at work on any irregularities or unsatisfactory conditions etc. The preferred approach is to speak with the immediate manager or senior executive in the concerned EURO CATER GROUP unit; however, if you feel insecure about discussing the problem with anyone in the management, you can file a report – anonymously or non-anonymously – within the framework of the Whistleblower Scheme.
All employees of EURO CATER GROUP, employees of EURO CATER GROUP’s subsidiary companies and all persons having a work-related attachment to EURO CATER GROUP are free to report. Persons attached to EURO CATER GROUP may e.g. be suppliers, external consultants, customers, cooperation partners, et al.
Any concerns involving employees of EURO CATER GROUP or other interested parties with a work-related attachment to EURO CATER GROUP may be reported. This applies to both employees and members of the Management Board or the Board of Directors of EURO CATER GROUP as well as other persons attached to EURO CATER GROUP, including suppliers, cooperation partners, lawyers, and accountants.
The Whistleblower Scheme is only for reporting serious concerns or suspicion thereof. It must be a matter of violation of laws, rules, politics, guidelines, etc. Less serious concerns such as e.g. dissatisfaction with salary conditions, inflexibility at work, etc. should never be reported via the Whistleblower Scheme but instead be reported via the usual communication channels.
The following are examples of serious concerns to be reported via the Whistleblower Scheme:
The above is merely a list of examples. If in doubt whether an observation you have made should be reported or not, we urge you to do so. We will respond to and deal with all reports, as we appreciate every single one of them. For purposes of the further investigation of a report, including covering the offence, it is decisive that you help clarifying the offence to best effect. A thorough investigation of a report is impossible if the report is unspecified or if it merely concerns very wide accusations without any detailed specification.
Reports must be filed via HjulmandKaptain’s Whistleblower Scheme available on the company’s website.
EURO CATER GROUP encourages that the Whistleblower reveals his/her name when reporting a concern in order for EURO CATER GROUP to be able to ask clarifying questions. However, a report may also be filed anonymously.
All reports are managed by EURO CATER GROUP’s legal counsel, HjulmandKaptain, who evaluates the qualifications of the person dealing with the report within EURO CATER GROUP. The report must subsequently be sent to the relevant person in charge within EURO CATER GROUP.
EURO CATER GROUP’s persons in charge for these matters are Trine Bøgelund, Henrik Ellegaard, Steen D. Pedersen, Lars Carlsson, and Johan Hagström. If the Whistleblower is concerned about filing the report to a specific one of the persons in charge, this must be stated in the report.
All parties involved, including EURO CATER GROUP and HjulmandKaptain will treat all reports as confidential.
Upon receipt of a report, the concern will be subject to an initial investigation.
If the report does not fall within the scope of the Whistleblower Scheme, turns out to be manifestly unfounded, or if the information therein is inaccurate, the personal data will be deleted immediately from the Whistleblower Scheme. It may be possible for certain concerns, which cannot be investigated within the Whistleblower Scheme, to be investigated and dealt with outside the scope of the Whistleblower Scheme.
If the initial investigation concludes that the report filed cannot be characterized as manifestly unfounded, it will be subject to a more thorough investigation. The concern will be dealt with internally and may have consequences for the employment of the reported person. The case will be deleted in the system but retained for up to five years in the personnel file of the affected person.
The case may be of such a character that it will be passed on to the Police for further investigation. When the Police (and the courts of law, where relevant) have finalized their investigations and any period allowed for appeal has expired, the case will be deleted from the system. The case may end up in the court system and the reported person may risk a penalty or a prison sentence.
It is important that the system is not used for accusations where a suspicion is directed towards innocent persons. Consequently, all reports must be filed in good faith and must be based on information into which the Whistleblower has gained direct insight and not merely on rumours.
A report falling outside the category of concerns to be reported via the Whistleblower Scheme (see item 4) will, if relevant, be handed over to EURO CATER GROUP’s whistleblower committe, including the CEO of the company concerned and deleted from the Whistleblower Scheme.
Reporting is made via the internet portal https://whistleblowersoftware.com/secure/eurocater
It is not possible to file a report to EURO CATER GROUP in any other way, e.g. by sending an email to the person in charge of the Whistleblower Scheme, due to the exchange of confidential personal data, which may never be sent in unencrypted form via the open Internet.
It is also possible to file a report to an external whistleblower scheme handled by the Danish Data Protection Agency. It is optional whether you wish to report via this internal Whistleblower Scheme or via the external scheme offered by the Data Protection Agency.
Information about the Data Protection Agency’s whistleblower scheme and about how to report is available on this link: https://whistleblower.dk/
EURO CATER GROUP urges you to use this scheme if you expect the reporting to be handled diligently, and if you feel secure that you will not be subject to retaliation.
When reporting, you will be given the opportunity to log into the system anonymously to see if the person in charge is asking further questions to the case or seeks further documentation. Any subsequent dialogue will be 100% anonymous, based solely on the Whistleblower’s willingness to log into the system and reply to the questions from the person in charge.
It is for the Whistleblower to decide whether to report anonymously. All reports filed in good faith are protected against any form of negative consequences (reprisals). Anyone attempting to carry out reprisals against a Whistleblower having reported in good faith will be met by disciplinary actions. If a Whistleblower chooses not to be anonymous, the company will treat the report as confidential, wherever possible.
If the Whistleblower has decided to reveal his/her identity, and legal proceedings are instituted against the reported person, the Whistleblower may, however, be called as a witness in any such proceedings.
EURO CATER GROUP will not accept any deliberate submission of false reports from any employee or any other person. Should a person deliberately make a false report, it may have legal consequences. If the person concerned is an employee of EURO CATER GROUP, the deliberate submission of a false report may have consequences for the employment of and even possibly resulting in the summary dismissal of the said employee. Accusations being both anonymous and unsubstantiated against individuals will be discarded by HjulmandKaptain and will not be dealt with by EURO CATER GROUP.
Basically, the Whistleblower’s identity will not be revealed to the person being subject to the Whistleblower’s report. The Whistleblower’s identity will, however, be revealed if the report turns out to be deliberately false.
The recipient of a report is obligated to notify the reported person about the concern being reported by the Whistleblower. In each individual case, it will be carefully considered when to give such notice to the reported person in order to avoid any consequences of the notice for the cover of the reported concern and the gathering of evidence.
Further, reference is made to the Privacy Policy for the Whistleblower Scheme, according to which the duty of disclosure under the General Data Protection Regulation is handled in relation to both the reported person and the Whistleblower.
No information about the Whistleblower will be disclosed even if the Whistleblower him-/herself might have chosen to reveal his/her identity. Please note, however, that a non-anonymous Whistleblower may be called as a witness if legal proceedings are instituted, see above.
The system used for registering the reports is hosted by Whistleblower Software ApS, viz. an independent company guaranteeing the security and anonymity of the system. The system does not log on any IP address or machine ID, and all data transmission and data retention will be encrypted. Only the person in charge has access to the case-handling part of the system. Additional information on the security is available in the Privacy Policy for the Whistleblower Scheme.
All reports will be securely retained in order for the information to be accessible only to the relevant persons. The Whistleblower Scheme is only accessible to EURO CATER GROUP’s legal counsel, HjulmandKaptain, who is also responsible for evaluating the competence of the person selected for dealing with the report within EURO CATER GROUP.
Any questions about the Whistleblower Scheme should be addressed to HjulmandKaptain, on +45 70151000.