Whistleblowing

At FUMAC A/S, we have a positive, passionate and proper approach to our work, just as we take pride in delivering the best quality in our work. We therefore find it very important that, based on our values ​​– Competence – Mutual respect – Quality – we ensure that irregularities or unethical behavior in the workplace come to light and that applicable legislation is complied with, which is why we have established a whistleblower scheme.

In a natural continuation of our values, we at FUMAC A/S want to show that we value a mutual understanding of each other’s points of view – both internally and externally in relation to our customers, suppliers and other business partners, just as we have a transparent decision-making process that concerns all the company’s stakeholders. We also want to maintain an open company culture where everyone can come forward freely and report suspected irregularities or illegalities regarding the company’s employees, management, board and suppliers.

The purpose of this whistleblower policy is therefore to explain how the whistleblower scheme works, including which conditions can be reported and how complaints received are handled.

The scheme implies that employees, board members and the company’s other stakeholders can make anonymous reports if there is a reasoned suspicion of serious and reprehensible conditions or illegalities that could damage the integrity of individuals, cause financial losses or otherwise cause serious damage to the company FUMAC A/S reputation.

Who can report?

All current and former employees, board members and the group’s other stakeholders (e.g. customers and suppliers) can report a problem to the whistleblower scheme.

Who can you report about?

Both violations and suspicions of violations committed by current and former employees, management, board members and business partners in general can be reported.

What can you report about?

You can only report matters to the whistleblower scheme which relate to serious wrongdoing – or suspicions thereof – that may have an impact on FUMAC A/S as a whole or the life or health of individuals.

Therefore, according to the law, notification can only be made about the following matters:
a. Serious violations or potential serious violations of the legislation in force at any time in relation to financial crime including, but not limited to, embezzlement, bribery, corruption, theft, violation of competition law, fraud and forgery, as well as assistance to third parties in such conduct
b. Serious breaches of occupational safety,
c. Serious conditions regarding discrimination, violence and harassment,
d. Serious environmental crimes.

Minor matters and matters relating to HR, such as dissatisfaction with salary conditions, harassment, incompetence, cooperation difficulties, absenteeism, violation of internal policies on smoking, consumption of alcohol or other forms of inappropriate behavior or behavior cannot be reported under the whistleblower scheme. Such conditions must be reported via the usual channels, e.g. by direct contact to the immediate superior or the HR department. If these matters are reported to the scheme, the notification will be deleted from the scheme.

Who processes your report?

FUMAC A/S whistleblower scheme is outsourced to the consultancy Odin2 ApS, which is responsible for the whistleblower scheme being administered according to current regulations. The technical solution of the whistleblower scheme is also provided and administered by the consulting company Odin2 ApS, which – as a data processor adopted by the company – will receive and register the reports received. The consulting firm Odin2 ApS reports directly to the chairman of the board of FUMAC.

The whistleblower unit is an external and neutral unit that cannot receive instructions from the company on how the unit should handle and follow up on concrete reports.

How is your report processed?

At FUMAC A/S, we listen to all reviewers and take every inquiry seriously. The reports received go to a few trusted employees at the consulting company Odin2 ApS, who receive the reports and carry out a closer screening of the report to assess whether it falls within the scope of the whistleblower scheme, or whether it turns out to be obviously unfounded. If there is a basis for a further investigation, this will be carried out by the consulting firm Odin2 ApS in agreement with the chairman of the board. Within 7 days, the whistleblower will receive a confirmation that the consulting firm Odin2 ApS has received the notification. Depending on the handling of the report and further progress, the whistleblower will receive feedback on the report within 3 months at the latest.

How do you report?

Notification to the whistleblower scheme is made electronically by sending an encrypted email to fumac(at)odin2.dk. Reports can be submitted in Danish and English. The whistleblower can always choose to remain anonymous.

What should you write?

Please write as much information as possible. The more detailed you can write your report, the better opportunities we have to investigate it.

We recommend that you at least answer the questions below:

• Name and telephone number (if you wish to provide it).
• What is your relationship with the company? (employee, former employee, future employee, business partner, etc.)
• What do you want to report?
• How did you find out about the matter?
• When did the matter take place? (write start, end and duration)
• Which people are involved in the matter?
• Which people can know more about the matter?
• Have you previously approached others about the matter?

Information about the report to the affected/reported person

FUMAC A/S is basically obliged to provide the person who has been reported with information about the reported matter. No information about the whistleblower’s identity or function will be passed on.

Deletion of information

If the report does not fall within the scope of the whistleblower scheme, the personal data will be deleted immediately. The information is also deleted when it is no longer necessary to store the information, including when the investigations have been completed. If a report is made to the police or other relevant authorities, the personal data will be deleted immediately after completion of the case with the relevant authorities. If, on the basis of the collected information, a disciplinary sanction is implemented against an employee who has been reported to the scheme, or it is otherwise necessary to continue to store the information, the information will be stored in the employee’s personnel file.

You are always welcome to contact the consulting firm Odin2 ApS, attention Senior Partner Peter D. Colmorn, petercolmorn(at)odin2.dk or mobile: +45 40 36 14 75.