Preamble and purpose
The purpose of this policy is to outline and explain the function of Relesys’ whistleblower scheme. The purpose of implementing a whistleblower scheme is to avoid reluctancy with reporting and addressing of serious matters.

Relesys’ whistleblower scheme shall, amongst other things, enhance the options for addressing illegal and/or serious matters in a secure and safe way, without the reporting person (hereinafter the “Reporter”) having to fear for negative consequences of the report.

Relesys encourages all persons to address problematic matters in an open dialog with relevant personnel, e.g. the nearest manager or main point of contact within the organization. However, if a problematic matter is not suitable for addressing and discussing openly, a report can be submitted in a confidential manner through Relesys’ whistleblower scheme.

Who is eligible to report
A report can be made by all employees of the Relesys Group as well as other persons with connection to Relesys, e.g. clients, suppliers, advisors, board members, interviewees, former employees etc.

What is eligible to be reported
Reports can concern infringement of EU law, serious infringements of law and other serious matters. Reports can also concern suspicion of the above-mentioned matters.

Some examples of infringement of EU law qualifying for a report is matters concerning financing of terrorism, environmental protection, public health, protection of consumers etc. Serious infringements of law and other serious matters could be infringement of tax law, bribery, forgery, hacking, theft, corruption, disregard of confidentiality duties, sexual harassment and other gross harassment, e.g. due to race, gender, color, language etc.

Reports can be made whereas an employee of Relesys or a person with close connection to Relesys has committed such infringements.

The whistleblower scheme should not be used to report minor and non-serious matters. Some examples hereof include salary matters, collaborative difficulties and insignificant matters. Such matters should be reported in accordance with internal policies and usual communication channels.

In case of doubt, Relesys encourages reports to be made through the whistleblower scheme rather than the matter not being reported. All reports will be registered, processed, and taken seriously.

How to make a report
A report can be made by sending a secure e-mail to whistleblower@relesys.net. A report shall be made in writing. It is not possible to conduct anonymous reports, however all reports will be subject to strict confidentiality and will be processed accordingly.

The Whistleblower Unit
Any reports made will be processed by Sally Domino, Head of Talent, who has been appointed Relesys’ Whistleblower Unit. The Whistleblower Unit will notify the executive management on reports, unless the reports concern matters regarding the executive management, in which case the Chair of the Board of Director will receive notification of the report.

Processing of a report
A report will be processed no later than 7 days after the report has been made. When a report is received, it will be registered, and an initial assessment of the matter will be conducted.

If the Whistleblower Unit assesses that the matter is governed by the whistleblower scheme, the report will be handed over to external advisors for further processing.

If the Whistleblower Unit assesses that the matter is blatantly unfounded or that the matter is not covered by the whistleblower scheme, the report will be rejected and deleted. The Reporter will, if possible, be made aware hereof.

A case will be deleted from the systems, when the case has been closed, either because the matter has been resolved or because the report could not be processed. Information provided along with the report as well as information gathered during the processing of the case will be stored, processed, and deleted in accordance with applicable laws.

If deemed necessary in order to avoid infringement of laws and other serious matters, information can be shared with the police or other public authorities. When possible, and under due consideration of the processing of the case in general, the Reporter will be informed of such sharing of information.

Confidentiality
It is not possible to conduct an anonymous report. However, all reports are handled with utmost confidentiality and the Reporter is protected cf. Law on Protection of Whistleblowers (Whistleblowerloven) and other applicable rules and regulations.

Processing of personal data under this whistleblower scheme happens in accordance with Law on Protection of Whistleblowers (Whistleblowerloven) as well as the GDPR and other applicable data protection laws.

Safety
In case of reasonable reports, the Reporter will be protected against reprisal of any kind. However, reports made in bad faith, may constitute negative consequences for the Reporter. The whistleblower scheme is internal. Only the Whistleblower Unit and necessary IT-personnel has access to the reports made.

Notification to the reported party/parties
Relesys is obligated to notify the reported party/parties, that a report has been made concerning them. Prior to any notification, an individual assessment will be made, determining what information can be shared and at what time. This ensures that notification of reported parties will not affect the processing of the reported matters.

The reported party/parties will not be notified as to who the Reporter is. This information is highly confidential. However, in case a report turns out to be substantial and a trial is initiated, the Reporter may be called as a witness.

External Whistleblower schemes

Relesys encourages all employees to utilize the internal whistleblower scheme insofar the report can be efficiently handled. However, in case the Reporter deems it better to report matters externally, there are several options to do so. Please see Schedule 1 following immediately after this whistleblower scheme.

Contact information
Should any questions arise regarding Relesys’ whistleblower scheme, including whistleblowing in general, please feel free to reach out to Head of Talent, Sally Domino at + 45 27 72 42 67 or sado@relesys.net. Inquiries will be processed confidentially.

Schedule 1 – External whistleblower schemes

External whistleblower schemes in Denmark