Whistleblowing

Protected individuals

Whistleblowing protection applies to more than just employees. Several categories of individuals may report misconduct and be protected.

Protection applies to employees, job applicants, volunteers, interns, consultants, subcontractors, company management and active shareholders.

Protection also applies to individuals who assist a whistleblower, such as union representatives, safety officers or colleagues. A whistleblower’s identity must be kept confidential. This protects the individual and places clear requirements on how reported information is handled.

A whistleblower must not be subjected to reprisals such as punishment, retaliation or disciplinary actions. A whistleblower cannot be held liable for breaching confidentiality obligations, such as non disclosure agreements, when reporting misconduct. Whistleblowers must not be prevented or discouraged from reporting.

Information covered by protection

Reporting must take place in a work related context. This includes information about misconduct that a whistleblower has obtained through current or previous work.

The whistleblower must have reasonable grounds to believe the information is true. Even if the information later proves to be incorrect, the report and the whistleblower remain protected, provided the report was made in good faith.

Protection applies to reports concerning:

• violations of applicable law or regulation
• serious misconduct of public interest
• actions or omissions that pose significant risk to individuals, society or the organization

Public interest

For misconduct to be considered of public interest, the information must concern matters relevant to society at large and not only to the individual whistleblower.

Public interest is often present when misconduct is serious. This may include environmental harm, consumer rights violations, risks to public health, improper handling of personal data, serious criminal activity or significant workplace safety issues.

Exceptions

There are certain general exceptions to whistleblower protection.

• Whistleblowers are not protected if they knowingly or negligently report false information.
  Matters that primarily concern individual employment conditions are generally excluded, as they typically lack public interest.
• Protection does not apply to reporting information that is subject to strict security or confidentiality requirements where disclosure would cause serious harm.
• The whistleblower must avoid disclosing more information than necessary. There is no protection for sharing information that is not required to understand the misconduct. In such cases, the whistleblower may be held liable.

Handling of reports of misconduct

As an organization, Transtema retains written and oral reports. Oral reports may be documented through recordings or written minutes. The whistleblower is given the opportunity to review, correct and approve the documentation.

Processing of reports

The internal reporting channel includes clear procedures for receiving reports, conducting follow up and providing feedback.

Reports are acknowledged within a reasonable timeframe, and feedback is provided once the matter has been assessed. Follow up is conducted thoroughly and in proportion to the nature and seriousness of the reported misconduct. Feedback typically includes information about investigative actions taken and general conclusions, to the extent appropriate.

Reporting at Transtema

The Transtema Group uses an external and independent party to manage the whistleblowing function. This ensures confidentiality, independence and objective handling.

The individuals managing reports are authorized to receive reports, conduct investigations, provide feedback and close cases independently, without requiring approval from the organization.

Individuals may report misconduct verbally or in writing. To ensure consistent and correct handling, reports are registered in Transtema’s whistleblowing system.