This policy outlines the guidelines for reporting and the rules for handling reports to Copenhagen Group's whistleblower scheme. The whistleblower scheme applies to Copenhagen Group A/S, CVR no. 28698941, and its wholly owned subsidiaries (collectively "Copenhagen Group").
In accordance with the Whistleblower Protection Act, Copenhagen Group's whistleblower scheme receives and processes reports concerning violations of EU law as defined in the Whistleblower Directive (EP/Rdir 2019/1937), serious legal violations, and other serious matters as defined in this policy.
The purpose of this policy is to make it easy for potential whistleblowers to report justified suspicions and discrepancies as early as possible and to assure whistleblowers that their reports will be taken seriously and investigated as required. It ensures that their confidentiality, and if desired, anonymity, will be respected, and that they can report without fear of personal consequences or retaliation.
A whistleblower is a person who reports illegal or questionable activities within companies, organizations, or public institutions where they are involved and which they believe in good faith to be true.
In Copenhagen Group, a whistleblower is someone who, in good faith, makes or attempts to make a report to Copenhagen Group's whistleblower scheme about matters covered by this policy.
Copenhagen Group'swhistleblower scheme can be used by:
Copenhagen Group's whistleblower scheme receives and processes reports concerning violations of EU law as defined in the Whistleblower Directive (EP/Rdir 2019/1937), serious legal violations, and other serious matters, including but not limited to reports on:
Copenhagen Group's whistleblower scheme does not accept or process reports from/about employees, partners, and suppliers who are generally dissatisfied with their cooperation with Copenhagen Group, their manager, colleagues, or the work environment in general. Such issues should be addressed through the usual channels in daily cooperation.
You can report issues toCopenhagen Group's whistleblower scheme by sending an email or a letter, or bycontacting one of the responsible members of Copenhagen Group's whistleblowerunit directly.
Reports can be sent viaemail to: whistleblower@cphgroup.com
Letters
Letters can be sent to ordelivered to Copenhagen Group A/S’s mailbox:
Copenhagen Group A/S
Skagerrakvej 4
2150 Nordhavn
ATTN: WHISTLEBLOWER
Personal Contact
Reports can be made toone of the responsible members of Copenhagen Group's whistleblower unit, asspecified in section 12.
· You can also report to Copenhagen Group's whistleblower scheme through anintermediary/employee representative. The intermediary must be a physicalperson who also has a work-related connection with Copenhagen Group and assistsyou with the reporting process. The assistance of the intermediary must beconfidential, and the intermediary will be protected in the same way as thewhistleblower, as described in this policy.
· Please avoid reporting to the whistleblower scheme by sending/deliveringunverified or unmarked letters to Copenhagen Group or leaving letters on thedesks of members of the whistleblower unit, as this poses a risk that yourreport may not be received and/or that the confidential information and/orpersonal data contained in your report may be accessed by unauthorized persons.
· If you report via email from an email account that is not CopenhagenGroup's mail account, for security and data protection reasons, please refrainfrom including or attaching materials that contain confidential or sensitivepersonal data. See also section 10. If you possess such materials, they can besecurely delivered in a sealed envelope marked "Whistleblower" andthe name of the person to whom the report is addressed, as specified in section12, to Copenhagen Group A/S’s mailbox at Sankt Annæ Plads 11, 1250 CopenhagenK, if you wish to remain anonymous. Alternatively, you can indicate in thereport that you wish to submit such materials, and you will receiveinstructions on how to transfer them securely and appropriately.
· All reports made through Copenhagen Group's whistleblower scheme are keptconfidential, ensuring that the whistleblower's identity is only known to thosewho need to know it in order to receive and process the report, and to anyrelevant public authorities, such as the police, to whom the report may need tobe forwarded.
· You can also report anonymously to Copenhagen Group's whistleblower scheme,and this will always be respected. However, whistleblowers are encouraged toreveal their identity, as anonymity can complicate or hinder investigations andaccurate conclusions if missing or additional information cannot be obtainedfrom the original whistleblower.
· If you do not report anonymously, you will receive an acknowledgment ofreceipt within 7 days of submitting your report.
· If you report verbally, the report will be documented either by recordingthe conversation (with your consent) or by preparing a summary of theconversation, which you will have the opportunity to review and correct bysigning the summary. If your verbal report is not immediately documented, youhave the right to request a physical meeting to document the report asdescribed above. This meeting will be arranged as soon as possible.
· Copenhagen Group's whistleblower scheme ensures careful follow-up on allreports. All reports are given high priority and are processed as quickly aspossible. The responsible person(s) in the whistleblower unit, who areappropriate for handling the specific report, will process the report andinitiate the necessary and relevant investigations. This includes determiningwhich other individuals and experts need to be involved. If your reportconcerns one of the responsible persons in the whistleblower unit, they willnot be involved in or responsible for handling your report.
· If you do not report anonymously, you may be asked to participate inmeetings or respond to inquiries during the investigations. Participation isnot mandatory, but you are encouraged to participate if asked, as yourinvolvement may be crucial for the investigations and for reaching accurateconclusions. If you choose to participate, you are entitled to bring acompanion from Copenhagen Group.
· The report and the results of the whistleblower unit's investigations willbe forwarded to Copenhagen Group's management or, if relevant, the board ofdirectors (unless the report concerns one or more members of Copenhagen Group'smanagement or board of directors, as specified in section 12). The managementor board will make the final decision on any sanctions or other consequencesresulting from the investigations, including possible reporting to the police,contractual actions, employment-related consequences, changes to internalprocedures, etc.
· If you do not report anonymously, you will receive feedback on your reportas soon as possible and no later than 3 months after receiving acknowledgmentof receipt. The feedback will include information on the actions taken orplanned in response to the report, such as filing a police report, initiatingfurther internal investigation, or submitting a report to the relevantsupervisory authority, along with the reasoning for such actions. Feedback willbe provided in compliance with applicable laws, particularly regardingconfidentiality, data protection, and privacy, which means that details andpersonal data may be excluded from the feedback. If investigations are notcompleted when you receive this feedback, you will be informed of the resultsonce the investigations are concluded.
· If your report is outside the scope of the whistleblower scheme, it may berejected. If deemed relevant, you may be encouraged to discuss the matter withyour manager or other departments. However, your report will not beautomatically forwarded internally or to other authorities. If your report isrejected from the whistleblower scheme, you will be informed of the rejectionand the reasons why.
· If your report is considered to fall within the scope of the whistleblowerscheme but, after due investigation, is found to lack sufficient evidence ordocumentation, the case may be closed without a definitive conclusion. In suchcases, you will also be informed accordingly.
Reports to CopenhagenGroup's whistleblower scheme are handled by the whistleblower unit. The membersof the whistleblower unit are listed in section 12.
The member(s) of thewhistleblower unit responsible for a specific report will act as impartialindividuals for that particular report and will undertake the following tasks:
All members of thewhistleblower unit are subject to a special duty of confidentiality regardingthe information contained in the reports to the whistleblower scheme and thesubsequent investigations.
Copenhagen Group isdedicated to protecting and supporting its whistleblowers. Whistleblowers areprotected from and must not face any form of retaliation, including threats orattempts of retaliation.
In this context,retaliation refers to any direct or indirect action or omission, such asharassment, discrimination, or other negative consequences for thewhistleblower's employment, cooperation, or other relationship with CopenhagenGroup, resulting from a report or intended report to Copenhagen Group'swhistleblower scheme, which causes or may cause unjustified harm to thewhistleblower.
Harassment anddiscrimination can include, but are not limited to, intimidation, bullying,exclusion, denial of deserved promotion, negative impact on salary or otheremployment terms, demotion, or dismissal.
The issues reported by awhistleblower to Copenhagen Group's whistleblower scheme, especially if thewhistleblower is an employee or close partner, often but not always, involveconfidential and loyalty obligations. This means that the whistleblower mightneed to override or worry about overriding their confidentiality and loyaltyobligations towards Copenhagen Group to uphold law and order, freedom ofexpression, and safety within Copenhagen Group. The whistleblower schemeensures that employees and close partners who, in good faith, make a reportcovered by this scheme, are not considered to have breached any legal orcontractual confidentiality or loyalty obligations and will not be held liable,provided they acted in good faith and had reasonable grounds to believe thereport was necessary to disclose an issue covered by the scheme.
A whistleblower who, ingood faith, makes a report about issues covered by this scheme will also not beheld liable for accessing the reported information, as long as such an act doesnot itself constitute an independent criminal offense.
Employees or others whoattempt to prevent an employee from reporting to Copenhagen Group'swhistleblower scheme, or who subsequently harass or discriminate against awhistleblower, will be confronted by Copenhagen Group's management and may faceemployment-related consequences, including dismissal or other relevantconsequences for the specific cooperation.
Whistleblowers whoexperience retaliation due to their report or intent to report (or assist withreporting) are encouraged to contact their immediate supervisor or a member ofthe whistleblower unit, as specified in section 12, as soon as possible.
Copenhagen Group takesits obligations and responsibilities in the whistleblower scheme veryseriously. It is crucial that the whistleblower scheme is respected and used inaccordance with its purpose. Therefore, reports made in bad faith or withknowingly false information or fabricated material will result inemployment-related consequences, including dismissal.
· The primary purpose of Copenhagen Group's whistleblower scheme is tofulfill its objectives in accordance with the law (see section 3), includingprotecting employees who report in good faith (see sections 1.4 and 9).Copenhagen Group also has a duty to protect the individuals being reported onand their personal data in compliance with applicable data protection laws,ensuring the utmost confidentiality within Copenhagen Group.
· Reports to Copenhagen Group's whistleblower scheme may contain personaldata about the whistleblower, witnesses, employees, or partners of CopenhagenGroup, which Copenhagen Group is obligated to process in accordance withapplicable data protection laws.
· The processing of personal data within Copenhagen Group's whistleblowerscheme is required for companies where the establishment of a whistleblowerscheme is mandatory under the Whistleblower Protection Act, section 22. Forgroup companies not directly legally required to have a whistleblower scheme,processing is conducted under Article 6(1)(f) of the General Data ProtectionRegulation (GDPR), where the company has a legitimate interest in receiving andprocessing reports to the whistleblower scheme, and it has been assessed thatthe interests and rights of the individual whose personal data is processed donot override this legitimate interest. In rare cases where sensitive personaldata is processed, it will only be done under Article 9(2)(b) of the GDPR, ifnecessary for the company (the data controller) to comply with its obligationsand specific rights in the field of employment, health, and social law, orunder Article 9(2)(f), if necessary for the establishment, exercise, or defenseof legal claims.
· The specific company within Copenhagen Group that is most closely connectedto your report, as outlined in section 1, will be the data controller for thepersonal data contained in the report. This company may share the relevantpersonal data with one or more companies within the Copenhagen Group or withprofessional partners (such as lawyers assisting with the processing of thewhistleblower report) if it is relevant or necessary for handling your reportor for following up on the information obtained during the investigation. Iflegally required, personal data may also be shared with authorities. CopenhagenGroup will not share personal data with parties outside the EU.
· Copenhagen Group will keep all reports and associated documents andmaterials, including any personal data, confidentially and for the periodnecessary to act upon and follow up on the reported issues, and further for theperiod Copenhagen Group is legally entitled to retain such personal data.
· Individuals whose personal data is processed in Copenhagen Group'swhistleblower scheme have specific rights, including the right to information,access, rectification, deletion, restriction, and data portability, asdescribed in Copenhagen Group's general data protection policy and here (to theextent it does not conflict with obligations in the whistleblower scheme). Theyalso have the right to lodge a complaint with the Danish Data Protection Agencyregarding the processing of their data.
· There are no automated decisions made in Copenhagen Group's whistleblowerscheme.
Copenhagen Group'swhistleblower unit prepares an annual report on all reports made to thewhistleblower scheme, which is reviewed by Copenhagen Group's board ofdirectors. This report and the annual review aim to ensure timely follow-up onall reports made to Copenhagen Group's whistleblower scheme. The informationand experiences from the reports are appropriately incorporated into optimizingCopenhagen Group's operations, organization, legal compliance, and ethics.
The whistleblower unitconsists of the company's chairman of the board and the company's auditor. Theycan be contacted via email at: whistleblower@cphgroup.com
Refer to section 5 fordetails on reporting.
