Convini’s whistleblower function:
Dealing with suspected irregularities

1. A report is made by filling in the form at the bottom of this page. In the form you can describe the suspected irregularity and supporting facts as well as submit a proposal for continued investigative measures. If you choose to remain anonymous, no information about you will be registered at all – not even your IP address or metadata for any files you submit. Please keep in mind that, in order to be covered by legal protections, you must have a reasonable basis for assuming that the information regarding the reported irregularities is true and that there must be a public interest in bringing these irregularities to light. (You can read more about this in the Questions & Answers section below).

2. When you submit your report, you will receive confirmation and a password which will make it possible for you to anonymously log into the Whistleblower Portal in order to receive regular feedback and follow-up questions from CRD. In the Whistleblower Portal you can also attach pictures and various documents in support of your report.

3. After receiving the report, CRD will follow up with you soon afterwards with a message sent in the Whistleblower Portal and notify you, after a legal assessment, about whether the report is covered by the Swedish Whistleblowing Act and the subsequent steps that will be taken in processing the matter. At this stage, it is common that you will be asked to reply to a number of follow-up questions. Also at this stage CRD will notify the appropriate contact person at Convini that a report has been received and provide a summary of it.

4. CRD will schedule a meeting with Convini’s whistleblower panel to present the matter and make recommendations for future handling and investigation. If you have chosen to remain anonymous, CRD will anonymise your report in terms of any identifying features and expressions. The dialogue with you as a whistleblower will continue in parallel.

5. In consultation with CRD, Convini’s whistleblower panel will decide on the measures to be taken.

6. In the event CRD conducts an internal investigation, you will receive regular feedback and they will maintain a dialogue with you, and you will also be afforded the opportunity to anonymously develop your report via a video or telephone conference. Where necessary, coordination will be carried out with the whistleblower panel, without disclosing your identity.

7. Following the completion of the investigation, CRD will report its conclusions in the form of a report or presentation with related recommendations. The investigation and its conclusions are independent and are carried out and reached based on the pre-assigned mandate.

Anyone who, in the context of work, has received or obtained information regarding irregularities within Convini and who belongs to any of the following personnel categories:

a) workers;
b) persons enquiring about or applying for work;
c) persons applying for or carrying out volunteer work;
d) persons applying for or completing a traineeship; Non-official translation
e) persons otherwise carrying out or standing ready to carry out work under an operator’s supervision and direction;
f) self-employed persons applying for or carrying out a service,
g) persons standing ready to take part in an enterprise’s administrative, management or supervisory body or who already do so;
h) shareholders standing ready to be actively involved in the company or who already are; or
i) persons who have belonged to any of the categories above and accessed or collected the information during their time in the activities;

The operator, its employees or its representatives. Irregularities must relate to circumstances at Convini.

• In summary, so long as the person filing the report belongs to one of the relevant categories of personnel, irregularities or improprieties of any type may be reported and covered by the Act so long as two conditions are met:

  1. there is a public interest in the irregularity being brought to light;
  2. the person filing the report has a reasonable basis for assuming that the information provided is true.

  Some examples of irregularities which are in the public interest include bias, bribes, fraud, misuse of tax funds, environmental crimes and dangers to life and health. While there is no requirement that a crime must be involved, the matter cannot relate merely to a trivial problem in the work environment or rules violations.

  The assessment of whether a public interest is present should be forward-looking and not historical and should entail that the public has an interest in the irregularity coming to an end or that the public has a need to protect itself from the circumstances. As a rule, the public interest is greater for operations financed with public funds than those financed with private funds. In addition, as a starting point, there is a public interest in the disclosure of violations of laws and regulations.

  As a rule, circumstances which pertain only to the whistleblower’s work or employment conditions, a conflict with another employee, or general objections are not in the public interest and thus are normally not covered by the legislation. The more severe, frequent or systematic the irregularity is and the more people it affects, the greater the social interest.

  The requirement regarding a reasonable basis to assume that the information provided is true refers to the fact that what is stated in the report must have some form of reasonable grounds. It need not be a matter involving proof but, rather, it is sufficient that there are concerns or suspicions which can be supported in a reasonable way, even if such concerns or suspicions are subsequently found to be incorrect. Examples of situations which are not covered by the Act include baseless accusations, spiteful mudslinging and spreading rumours.

Convini has assembled a whistleblower panel for the whistleblowing function. The whistleblowing panel’s principal task as the qualified unit is to review matters received and, in consultation with CRD, take decisions regarding measures within the context of addressing the respective reported matter.

As members of the whistleblower committee Convini’s management has unanimously appointed the following employees. Xt is the convener of the whistleblower committee and the contact for CRD.

In the event a member is suspected of being biased in relation to the contents of the report, such member shall not participate at all in the administration of the matter. If you already suspect that there is bias, it is important that you mention it when submitting your report.

In the event the whistleblower panel determines within the context of administering a matter that there is cause for another unit or representative at Convini to pursue further measures as a consequence of what has come to light in the matter, the information which is necessary in order for those measures to be able to be taken shall be provided to that unit or representative provided that it is in accordance with the purposes of the legislation.

CRD is responsible for the receipt, assessment and administration of submitted reports as well as all communication with the whistleblower. Following consultation with Convini’s whistleblowing panel, CRD may be allocated an independent investigation mandate and shall then be responsible for the investigation as a whole, which entails investigative measures as well as subsequent conclusions and recommendations decided by them.

A persuasive reason to allow an outside party to be responsible for the whistleblowing function is the possibility to offer you as the whistleblower anonymity and a greater measure of security and independence. Accordingly, as regards your identity and your personal data, there is a duty of confidentiality on the part of CRD in its relationship with Convini. In addition, CRD independently determines whether any of the information you have provided poses a risk of indirectly identifying you in an undesirable way. This also means that there is a possibility for you to supplement your report by telephone or video conference while preserving anonymity.

The report is submitted via a whistleblower portal which has been developed in Sweden and has been tailor-made with the whistleblower’s need for anonymity and security in mind. This means that you are completely anonymous and can submit and follow up on your report in encrypted form by means of a personal log-in function. The portal saves no information about you whatsoever, not even an IP address. If you wish to upload a document for the investigator who is responsible, the so-called metadata (information regarding which person or user has created or edited a file) is erased automatically. All material which is stored with CRD is erased by law when it is no longer necessary and not later than two years following the conclusion of the investigation.

All information that can identify you directly or indirectly as the whistleblower is covered by secrecy or a duty of confidentiality.

As regards your identity and your personal data, CRD is subject to a duty of confidentiality in its relationship with Convini. In addition, CRD independently determines whether anything in the information you have provided poses a risk of indirectly identifying you. This also means that there is a possibility for you to supplement your report by telephone or video meeting while preserving anonymity.

The possibility for anonymity does not apply in the event you provide information concerning the safety of the Swedish realm, violates in some other manner a qualified duty of confidentiality, you commit a crime by virtue of your report, or where the matter becomes the subject of legal action. (See, also, the question and answer regarding the duty of confidentiality and information subject to secrecy.)

The new Swedish Whistleblower Act states that the protection provided to the whistleblower is enhanced and entails that Convini, on penalty of damages, may not prevent or attempt to prevent you from submitting a report.

In addition, Convini may not, in any form, engage in reprisals against you or your relatives or any third party who has assisted you in the report so long as you do not commit a crime in doing so. In addition, it is prohibited for Convini to attempt to ascertain your identity.

In parallel with the whistleblower legislation, there is a constitutionally protected freedom of communication and freedom to acquire information and related prohibitions against investigation and reprisals. These rights may be found in the Swedish Freedom of the Press Act and the Swedish Fundamental Law on Freedom of Expression.

Information which is covered by a duty of confidentiality – but not information that is qualified* – may be disclosed if you have a reasonable basis for assuming that it is necessary to disclose the irregularity. It is important to keep in mind that, even if the information may be disclosed, this does not apply to the documents in which the information appears.

You also have a right to obtain information to which you are actually not entitled so long as obtaining it does not constitute a criminal act and is necessary in order to disclose the irregularity.

*Information which, in accordance with the Swedish Public Access to Information and Secrecy Act, is protected by a qualified duty of confidentiality concerning matters such as national security or sensitive health information, may never be disclosed, not even orally.

CRD does not save any IP addresses or information at all regarding the person who uses the Whistleblower Portal. As regards CRD’s client, a list may be kept in certain cases of the websites visited by its employees at work. If you suspect that that is the case, in order to further protect your identity, you can use a computer or unit outside your employer’s network when you submit your report or log in to the Whistleblower Portal.

Reporting via the Whistleblower Portal provides the best conditions for anonymity, replies and efficient administration. If you desire, you can submit your report also by letter (CRD Protection AB, Norra Obbolavägen 89, 904 22 UMEÅ) or by telephone (+46 90-77 79 00).