Instructions regarding the Whistleblowing methods
Responsibility is part of Kojamo’s DNA. We wish to operate transparently and do what is right and make sure that all of our employees, stakeholders, and partners can have their voices heard if they notice malpractice or suspected misconduct. In their day-to-day work, all of Kojamo’s employees, partners and stakeholders are required to observe Kojamo’s values, Code of Conduct, business practices, policies and the legislation applicable to the company.
Shall you notice a suspected misconduct, or you have a well-founded reason to believe that an action or neglect of Kojamo or an employee, a partner or a stakeholder of Kojamo will likely cause significant harm to the organisation or to a single individual you must immediately contact your superior or a contact person in Kojamo. If, for some reason, you are unable to report your suspicions to said person you can share it with us by using the Kojamo Whistleblowing Channel. Link to the Whistleblowing Channel can be found at the end of this page. You can always request a meeting with the General Counsel of Kojamo to discuss your suspicions in confidence.
Through the Whistleblowing Channel you can report any concern regarding an issue that does not conform to our values or Code of Conduct. Reports may concern also violations or suspected violations of the rules and regulations pertaining to the financial market (insider dealing or market manipulation) or actual or suspected infringements of Kojamo’s Corporate Governance principles or Code of Conduct. Through the Whistleblowing Channel you can make your report anonymously but to expedite the clarification of suspected misconduct, we appreciate if the reports were made with your name and contact details.
In issues regarding rental of houses and occupancy of our premises you can contact our customer service (email@example.com).
Instructions regarding the Whistleblowing Channel
All reports are processed carefully and confidentially by designated people in Kojamo’s legal affairs unit. If necessary, and by applying high level of confidentiality, people with required knowledge and expertise may be included in the investigation. Reports and data related to the investigation may only be accessed by the people conducting the investigation and they may only be disclosed to parties, and to the extent, that absolutely need the data to carry out the investigation.
Reports regarding suspicions are subject to the following principles:
- All of the reports are processed confidentially.
- The targets of the suspicions and any others linked to the suspicions may not review the reports.
- No one taking part in the investigation may seek to discover the identity of the person who submitted the report in any manner.
The person submitting the report does not need to present definite proof to support their suspicions. However, the person in question must be convinced of their authenticity and act in good faith. Giving false information intentionally may result in a liability for the financial damage caused to the subject.
If the person reporting through the Whistleblowing Channel gave her/his name and contact details, she/he will be responded within seven days for notice of receipt and initial questions. Similarly, she/he will be given information regarding the potential actions based on the report once the investigation is over or in any case no later than in three months from the notice of receipt.
Protection of the person submitting the report
In the legislation regarding the whistleblower protection (1171/2022), the employer, or other organisation that utilises direction and supervision to the person reporting, and for whom the person is working for or to which the person is due to her/his work otherwise in connection with shall not take any retaliative measures or treat the person with unjustified detriment due to the fact that the person has made a report.
The prerequisite of the whistleblower protection is that the report of the malpractice or the suspected wrongdoing is made primarily to Kojamo’s internal whistleblowing channels. The prerequisite does not apply to reports made from alleged violations of the rules and regulations pertaining to the financial market or the following incidents where the person reporting can always report directly to the whistleblowing channel of the Chancellor of Justice or to the competent authority if:
- the organisation does not have an internal whistleblowing channel or the person reporting was not given an opportunity to make a report through the internal whistleblowing channel;
- the person reporting has a reason to believe that the internal report has not led into necessary action within the time frame of the legislation;
- the person reporting has a reason to believe that the wrongdoing cannot be efficiently rectified through company’s internal report;
- the person reporting has a reason to believe that due to the report she/he is at risk of being a target of retaliative measures.
The identity of the person reporting will be kept confidential throughout the process and shall not be disclosed to people targeted in the report or other people not involved in the process of investigation.
If the report leads to a criminal proceeding, the person reporting must be prepared that the identity would be revealed during the trial. Is such case the person reporting will be notified.
Protecting the person named in the report and their right to obtain information
Information collected from reports is processed confidentially as well as in compliance with the applicable data protection regulations and other regulations. The rights of the persons named in reports are governed by data protection legislation. Such a person has the right to obtain the information applicable to themselves and require that the information be rectified in case the information is incorrect, inaccurate or outdated. Nonetheless, the protective measures taken to prevent the destruction of the evidence or other processing or investigation of the report shall have precedence over the aforementioned rights. The appropriate cooperation procedure has been discussed with the personnel prior to the deployment of the whistleblowing reporting system. In addition, an impact assessment has been carried out in accordance with section 35 of the General Data Protection Regulation (GDPR).
Destruction of information
All information will be destroyed once they are not needed for the investigation or for the further actions. In majority of the cases the information will be destroyed within two months (60 days) from the investigation. The personal information that clearly have no relevance to the processing of the report, will be destroyed without unnecessary delay. The investigation documents will be anonymised in such a way that names, addresses and all other information that may directly – or indirectly in connection with other information – reveal the identity of the person who submitted the report or the person referred to in the report.
All information will be destroyed latest on the fifth anniversary of the report unless the preserving of the information is necessary in order to comply with the rights or obligations within the legislation or in order to draft or present a legal demand or to defend from one.
Reporting the results
The results of the investigations are reported to the Kojamo Audit Committee and to the Board of Directors.
The amount of reports made through the Whistleblowing Channel are reported on a yearly basis in the Kojamo plc’s Annual Report.
Page updated 14 April 2023