Whistleblower scheme

Uhrenholt places great emphasis on securing and protecting internationally proclaimed standards concerning human rights, labour and environment. Bribery and corruption are fundamentally inconsistent with Uhrenholt’s values and business principles.

Equal treatment of all our employees, customers and suppliers, and good business ethics, are key elements of Uhrenholt’s operations.

Therefore, we strongly encourage you to speak up if you suspect or witness any matters of concern. We will take all reports made under our whistleblower scheme seriously.

Please read this before reporting your suspicion or concern.

2. Who can submit a report?

You can submit a report if you are a former or current employee in Uhrenholt, a supplier, a business partner or customer, or if you otherwise have a connection to Uhrenholt.

What can be reported?

You can make a report through the whistleblower scheme if you have knowledge or suspicion of illegal activities or serious irregularities in Uhrenholt such as serious breaches of applicable laws and regulations and other serious matters, including breaches of EU law as set forth in the Directive of the European Parliament and of the Council on the protection of persons who report breaches of Union law, including the following:

• Criminal offences, including fraud, embezzlement, misuse of assets, forgery of documents, accounting manipulation, bribery, corruption, money laundering and terrorist financing
• Breaches in procedures or acts of negligence which compromise food safety
• Competition law breaches
• Serious breaches of occupational health and safety legislation
• Significant breaches of environmental regulations and pollution of the environment

• Breach of professional secrecy

• Serious or repeated breaches of important internal guidelines in Uhrenholt
• Serious workplace conflicts, e.g. severe bullying, harassment, discrimination, physical violence, threats and sexual abuse

 

The above are examples only. If you are in doubt as to whether or not your report falls within the scope of the whistleblower scheme, we encourage you to use our whistleblower scheme. The report will then be assessed, and you will receive feedback on whether your report is covered by the whistleblower scheme.

Other matters, including HR matters, complaints about other employee’s behaviour or incompetence, dissatisfaction with salary conditions, including minor breaches of Uhrenholt’s internal guidelines on sick leave, alcohol intake etc. are not covered by the scope of the whistleblower scheme. These types of matters must be raised in a dialogue with an immediate manager or your local HR department. 

Do not use the whistleblower scheme to report events that pose an immediate threat to life or health. If you need urgent help, please use the public emergency services.

While you are encouraged to report any real or suspected breaches of the law through this internal whistleblower scheme, you may also decide to use the external whistleblowing reporting schemes set up by the national authorities in the respective relevant countries.

PwC

Our whistleblower scheme is operated by an external third party, PwC (PwC Statsautoriseret Revisionspartnerselskab "PwC"). PwC is an independent audit, tax and advisory firm, who receives reports on behalf of Uhrenholt to ensure an independent and anonymous channel for you to report your concerns.

PwC will make a preliminary assessment of whether the report falls within the scope of the whistleblower scheme. PwC will then assess who can handle the whistleblower report in Uhrenholt impartially and competently, ensuring the report is not forwarded to a person whom the whistleblower report relates to directly or indirectly, or where there may be a risk of conflict of interest.

After the preliminary review, the report will be forwarded for further processing in Uhrenholt.

The CEO of Uhrenholt

The CEO of Uhrenholt is the overall responsible for the whistleblower scheme in Uhrenholt. The CEO is responsible for proper management of the whistleblower scheme and diligent follow-up on whistleblower reports. The CEO is responsible for deciding whether investigations of whistleblower reports shall be conducted and for ensuring that whistleblower reports are handled in compliance with applicable rules.

Confidentiality, objectivity, and anonymity

All investigations of whistleblower reports are carried out with due respect for maintaining and ensuring independence, confidentiality, data protection and data security. All information will be kept confidential to the fullest extent possible.

All whistleblower reports are handled by authorized staff within PwC and Uhrenholt. The designated staff has a special duty of confidentiality in relation to the information contained in the whistleblower reports. The duty of confidentiality covers information that is included in the report, including the name of the whistleblower and persons mentioned in the whistleblower report. If a report gives rise to the initiation of further investigation, additional information collected in that connection will not be covered by the duty of confidentiality.

You have the right to submit your report anonymously. If you choose to remain anonymous, do not disclose your name or any other personally identifiable information, such as your address, email, or telephone number.

If you choose to remain anonymous, you should know that it may complicate the investigation of your concern or suspicion. We therefore encourage you to disclose your identity when making a report in the knowledge that you can do so without having to fear intimidation, harassment, retaliation, reprisals, discrimination, or adverse employment consequences because of such report.

If you decide to disclose your identity to PwC, your identity will only be known to PwC. Your identity will be kept anonymous and not disclosed to Uhrenholt unless you give explicit consent to disclose it to Uhrenholt.

How is your report handled?

PwC will confirm the receipt of the report directly to you within seven days of receiving your report, if possible.

PwC initially makes an assessment of whether the report is covered by the scope of the whistleblower scheme and evaluates who can handle the whistleblower report to ensure that the whistleblower report can be handled by an impartial, independent and competent designated person in Uhrenholt.

If the report does not fall within the scope of the whistleblower scheme, it will be forwarded to Uhrenholt with a notice to this effect. Consequently, as there is no basis for processing the report, it will immediately be deleted.

If the report falls within the scope of the whistleblower scheme and there is a basis for conducting an investigation, PwC forwards the report to Uhrenholt, who will determine the appropriate steps to take and whether an investigation of the matter will be initiated.

Uhrenholt may conclude the following based on the investigation:

• The investigation is closed if the report is unfounded
• The investigation is closed by giving a reprimand/warning
• The investigation is closed with an expulsion/dismissal of an employee
• The investigation is closed with a recommendation to change policy/procedure/guidelines
• The investigation is handed over to the police or other relevant supervisory authorities for further investigation

You will be informed of the actions taken or envisaged based on the report, the reason for choosing such actions, and any results within three months of making the report, to the extent possible and in accordance with any applicable confidentiality limitations or restrictions. The content of the information given to you, and the level of detail, will be dependent on the type of breach reported and actions taken.

Personal data

Personal data and information submitted through the whistleblower scheme is processed for the purpose of establishing a whistleblower scheme in Uhrenholt that can be used for reporting potential criminal offences and/or irregularities of major concern to Uhrenholt.

The legal basis for investigating any unethical and/or illegal conduct or activity, irregularities, wrongdoing or dangers at work in Uhrenholt, so that Uhrenholt can prevent and avert illegal and serious conduct and activities and for the processing of personal data follows from Regulation (EU) 2016/679 (“GDPR”), Article 6 (1) on the processing of personal data, Article 9 (2) on the processing of special categories of personal data, and in Article 10 on personal data relating to criminal convictions and offences processing of personal data which is necessary for Uhrenholt to pursue a legitimate interest in being able to investigate any criminal offenses or other unlawful conduct in the whistleblower reports.

Uhrenholt collects and processes personal data for the purpose of pursuing the legitimate interest of Uhrenholt in ensuring compliance with applicable laws throughout all of Uhrenholt’s operations. This is in accordance with point f in Article 6 (1) under the GDPR.

Uhrenholt collects and processes personal data about you for the purpose of complying with legal requirements in order to meet a legal obligation imposed by law, by regulation and/or national rules specific for the reported matter. This is in accordance with point c in Article 6 (1) under the GDPR.

Uhrenholt collects and processes the following personal data in accordance with the outlined purpose and legal basis:

• Information regarding the reported matter - potential breach of law, criminal offence, violations of internal policies, procedures and guidelines in Uhrenholt or other serious matters
• Documents, information or evidence supporting the reported matter, and other information relevant to the investigation of the matter
• The whistleblower’s name, email and telephone number, including other potential identifiable personal information
• Names of any persons mentioned in the whistleblower report, including other potential identifiable personal information, and names of persons within Uhrenholt or outside Uhrenholt who know or may know about the reported matter

When your personal data is registered you have the right to submit a complaint with the relevant independent authority that supervises compliance with the rules on protection of personal data. You can access a complete list of European supervisory authorities here: https://edpb.europa.eu/about-edpb/about-edpb/members_en

 

Whistleblower protection

Uhrenholt does not tolerate harassment and retaliation against whistleblowers. No whistleblower will be victimized for raising a matter through the whistleblower scheme as long as has raised a legitimate concern in good faith.

Uhrenholt does not accept that an employee intentionally submits incorrect or misleading information via the whistleblower scheme. If an employee knowingly makes a false report, it can result in negative employment law consequences, including termination of employment.