The whistleblower function
BAMA Nordic’s whistleblower function is for reporting suspected irregularities within BAMA Nordic’s operations
and consists of:
- A web based reporting channel
- PwC:s that are managing the whistleblower function and receiving the incoming whistleblower reports and
- Specially appointed internal persons within BAMA Nordic who decide how incoming whistleblower reports should be handled with appropriate measures.
The Swedish Whistleblower Act (law 2021:890) entails that a group of persons can report misconduct within
the organisation in which they are active, but also to ensure that these are protected against retaliation. In addition to employees, workers and hired personnel, interns, consultants and people who perform work under BAMA Nordic’s control are included in the protected circle of persons.
A whistleblower is a person who, in a work-related context, became aware of, or obtained information about, misconduct and reports about it. A work-related context means a person’s current or previous work at BAMA Nordic.
Whistleblowers must be able to report misconduct both in an internal reporting channel (BAMA Nordic’s whistleblower function) and to specially appointed authorities (external reporting channels – see below).
BAMA Nordic’s whistleblower function does not replace the possibility of reporting misconduct to the his or her manager or HR manager, but is only intended to function as a complement to these if for some reason you do not want to report via the regular reporting channels.
What situations can be reported
A report to the whistleblower function must refer to information about misconduct. It must be misconduct of such a nature that there is a public interest in their being brought to light, rectified or discontinued. Examples are suspicions of fraud, corruption or other forms of financial crime, disregard of work environment legislation, suspected environmental crime or serious forms of systematic harassment. Attempts to conceal misconduct may in themselves also constitute misconduct. However, information that only concerns the whistleblower’s own work or employment should not be reported to the whistleblower function.
According to the Whistleblower Act, BAMA Nordic can not prevent or attempt to prevent reporting, or because of reporting to take retaliation against a whistleblower, someone at BAMA Nordic who assists the whistleblower in reporting, someone at BAMA Nordic who is connected to the whistleblower or a legal entity that the whistleblower owns, works for or is otherwise associated with.
The whistleblower must, at the time of reporting, believe that the information about the misconduct is correct. If a whistleblower is subjected to retaliation, there is a right for compensation.
When reporting to BAMA Nordic’s whistleblower function, a whistleblower can choose to remain anonymous.
If a person intentionally reports false or misleading information, that person is not protected under the Whistleblower Act. If the person making the report has been involved in the reported irregularities, he or she is not protected from disciplinary or legal action by reporting the matter.
How to report to the whistleblower function
Reporting to the whistleblower function can be done via a separate link to the whistleblower function where the whistleblower chooses the reporting channel: In writing via a web-based questionnaire, a phone call or in a physical meeting. When the report is complete, the whistleblower receives a special login code that must be used to follow the case and receive feedback on the case.
How is a report handled
PwC carries out an initial assessment of incoming cases. After PwC’s initial assessment, BAMA Nordic’s internal recipients get access to the case and the assessment in the whistleblower system. If a whistleblower report contains information that includes one of BAMA Nordic’s internal dedicated persons, this person or persons will not be included in the further process to handle the whistleblower report.
BAMA Nordic has appointed special persons internally within BAMA Nordic to handle incoming cases. These persons have been selected to act independently and autonomously in the handling of incoming cases.
The person handling a reported case must not unauthorizedly disclose information that could reveal the identity of the whistleblower or of any other individual (both natural and legal person) appearing in the case.
The whistleblower will, via the digital whistleblower system, receive confirmation that a case has been received and the associated measures.
How reporting can be done to the competent authorities via the external reporting channels
BAMA Nordic’s whistleblower function is an internal reporting channel. An external reporting channel, on the other hand, is a channel established by an authority for handling reporting of violations that are within the authority’s area of responsibility and which may include misconduct by any public or private operator.
An external reporting channel can, for example, be used if a whistleblower does not believe that reporting to the internal reporting channel (in this case BAMA Nordic’s) would involve objective and objective handling. This applies on the condition that it concerns issues that fall within the scope of the competent authority’s area.
The authorities appointed by the government appear on the following page: