Whistleblowing of suspected or known wrongdoing

Primarily, you are encouraged to report known or suspected wrongdoing to a manager or a manager’s manager. If you prefer, speak to someone in the Human Resources or any Legal function instead. If you feel uncomfortable doing this, you may report suspected or known wrongdoing through any of the channels listed below. You may report confidentially and anonymously.

Whistleblowing is open to employees of Tyréns Group and all subsidiaries, to business partners of Tyréns Group and all subsidiaries, and to the general public.

Why do we have a whistleblowing system in Tyréns?

Whistleblowing is part of our push for a Tyréns Group with strong values and ethics. It enables us to raise concerns about wrongdoing when we are not comfortable using other channels. We know that whistleblowing in the workplace helps us detect and deal with wrongdoing that could otherwise cause great harm. The existence of a whistleblowing system in [Tyréns] is stipulated in the Tyréns Group Code of Conduct and in the Tyréns Group Business Ethics Policy.
It is also a legal requirement for companies to provide channels for whistleblowing.

What can you report?

The whistleblowing system is intended for the reporting of suspected or known instances of wrongdoing that are:

• A breach of the law, such as anti-competition law, harassment and equal treatment laws, corruption laws, theft, fraud, intellectual property laws and other laws relating to [Tyréns] activities.
• A breach of the Tyréns Group Code of Conduct, Business Ethics Policy, Sustainability Policy, Financial Reporting Policy or any other policy of Tyréns Group or [Tyréns], relating to harassment, equal treatment, environment, conflict of interest, anti-competition, reporting standards, or other areas covered by the policies.
• In conflict with Tyréns Group values and/or
• In some way, may directly or indirectly damage the reputation of Tyréns Group or any subsidiary.

Whistleblowing should not be used for:

• Business or employee negotiations, such as salary or employment contract negotiations,
• Quality complaints that do not constitute wrongdoing,
• Complaints regarding issues that do not constitute wrongdoing as listed above, and/or
• Rumours or misinformation.
  You do not need to have firm evidence for expressing a suspicion, as long as it is done in good faith, that is, with the sincere intention of being fair, open, and honest.

Deliberately reporting false or malicious information constitutes an abuse of the whistleblowing process.

Which reporting options do I have?

If you feel uncomfortable reporting a known or suspected instance of wrongdoing to a manager, a manager’s manager, Human Resources or the any Legal function, you may use any of the channels below.

Tyréns Group level

These channels are the ones available at Tyréns Group level. Reports are received by Frank Pedersen, the CLO of the Tyréns Group.

• E-mail. Send an e-mail to frank.pedersen@tyrens.se
• Telephone. Call Frank Pedersen on +46 73 431 65 85
• Meeting. Arrange a meeting with Frank Pedersen through e-mail or telephone above.
• Whistleblowing system. Click here to get directed to an encrypted whistleblowing system managed by an external supplier. In the link you can read more about how the system works and protects your anonymity. When your report has been submitted, it will be handled by Frank Pedersen.

As a whistleblower, you are protected

You can choose to be anonymous and your identity will not be disclosed, unless:

• such disclosure is strictly necessary for the proper handling of the report;
• you have given explicit consent to such disclosure in advance;
• such disclosure is required by law or in subsequent legal proceedings, or
• an Investigation has found that the report was submitted in bad faith.

It is expressly not allowed to attempt to identify a whistleblower.

As a whistleblower, you are also protected by a non-retaliation principle. Any negative consequences to you, as a consequence of reporting wrongdoing in good faith, is considered a serious offence and in breach of the values and Code of Conduct of Tyréns, and could lead to sanctions, including disciplinary action or termination of the business relationship. Harassment, bullying and negative career or compensation impact are examples of such negative consequences.

Your report will be evaluated and feedback provided

After your report has been received, it will be evaluated and managed according to a set process. If the evaluation shows that there could be merit to your report, it will be investigated.

You can contact the receiver in question for information about the case.

When the process is complete, you will be contacted by the receiver and notified about the conclusions and results from your report, without details or information that may compromise the integrity of Tyréns or the investigation.