Whistleblower Policy

At elite Hotels strive for a culture and environment with open discussions, embracing differences and respecting one another’s opinions, and where dialogue is held if a potential problem arises within the organisation. In this Whistleblower Policy, we state how employees can raise the alarm in the case of misconduct without breaching the loyalty obligation in their employment contracts and suffer from work-related actions and other negative consequences.

Even if it is not a misconduct which requires the employee to alarm in accordance with this policy, we encourage all employees to bring up potential problems within the organisation with their immediate superior as the first point of contact.

Whistleblower Policy

Purpose

The purpose of our Whistleblower Policy is to provide clear guidance on when and how misconduct can be reported in situations when it is not applicable to use the standard means for reporting. All disclosure of misconduct is to be handled in a fair and correct manner.

General guidelines

Whistleblowing in this policy refers to someone raising the alarm regarding an ongoing, planned or previous misconduct in a work-related context within the business and there is a public interest in revealing it.

Work-related context means that the person reporting must have received information of the misconduct during a current or previous employment. Misconduct can refer to both intentional actions or accidents for which no one person could be held accountable.

For the policy and the law to be applicable, it is required that there is a public interest in finding out about the misconduct. In most cases, the law does not apply to reporting of matters that only concern the reporting person's own working or employment conditions.

In which situations should the employee alarm?

The employee has the possibility to raise the alarm when it is a matter of misconduct taking place within the organisation of the employer and there is a public interest in finding out about it. The irregularities must have been performed by a person in a leading position. The employee’s intention behind raising the alarm is not significant. Although this policy is primarily aimed at employees the Act on the Protection of Persons who Report Malpractice (the Whistleblower Act) is also applicable outside the employer-employee relationship. This means that non-employees are also entitled to protection under the Whistleblower Act as long as the reporting takes place in a work-related context and the law's criteria for protection are met.

How should you as an employee alarm?

The procedure to raise the alarm does not require any specific form. However, we have chosen to use an independent web-based whistle-blowing function to simplify for the person intending to alarm. It is also possible to alarm by phone and by post.

A person wanting to report misconduct always has the option to alarm through external reporting channels which are provided by several authorities. As an employee you also have the option to contact either your union safety officer or trade union organisation to receive advice about a potential reporting. We view this positively and the employee risks no retaliation or preventive measures in connection with counselling.

It is not required that the employee has detailed knowledge of the suspected misconduct. The protection against reprisals also applies to unfounded and unjustified alarms. We presume that the employee alarming is sincere and that no employee alarms over information they know to be not true or events they know will never take place.

People who have access to incoming reports have a responsibility in their duty to handle the alarm with a very high level of discretion. Neither the identity of the whistle-blower nor anyone else whose identity appears in the case will be disclosed. Personal data may only be processed if it is necessary for the case and data that is accidentally collected but which is not deemed relevant must be deleted immediately.

What happens when an alarm is received?

As soon as an alarm is received about misconduct, the whistleblower will receive a confirmation that the organisation has received the alarm.

The organisation conducts an instant analysis of the details provided by the employee to assess whether further investigation is warranted. The next step in the process is that the organisation decides on how to handle the case. When necessary, the case will be sent to external parties, for instance, unbiased accountants, the Police, or other legal authorities. The organisation will, to an appropriate extent, regularly update the whistleblower on the progress of the case.

Protection against blame, reprisal and harassment

Under no circumstances do we tolerate that an employee that has been alarmed of misconduct, in accordance with this policy, is subjected to any form of blame, reprisal or harassment as a consequence of the whistleblowing. All forms of blame or sanctions will be handled instantly and will result in disciplinary action.

Scope

Our Whistleblower Policy covers not only our employees but also a few other categories of people that come into contact with our organisation such as jobseekers, trainees, consultants and other contracted staff.