Instructions for cooperation partners regarding the whistleblowing procedure
Kojamo plc (hereinafter referred to as “Kojamo”) wants to operate transparently and sustainably. The purpose of Kojamo’s whistleblowing procedure is to ensure that our management and control system works and provides the opportunity to report suspected misconduct – anything in violation of the organisation’s values, Code of Conduct or business practices.
The whistleblowing procedure is an advance warning system available to Kojamo’s employees and stakeholders that aims to reduce risks to the company. It is an important tool used to promote compliance with the Code of Conduct and maintain customers’ and other stakeholders’ trust in Kojamo.
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.
These instructions explain how Kojamo’s cooperation partners can report a concern regarding an issue that does not conform to our values or Code of Conduct and which may have serious consequences for our organisation or an individual. For instance, the reports may concern financial or administrative violations, violations or suspected violations of the rules and regulations pertaining to the financial market (actual or attempted insider dealing or market manipulation) or actual or suspected infringements of Kojamo’s Corporate Governance principles or Code Conduct.
The person blowing the whistle should take into consideration that, according to the data protection laws, only personal data linked to crimes may be reported and processed.
When is it appropriate to use the whistleblowing procedure?
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. Accusations should not be put forward for the purpose of attacking another person if they are known to be unfounded.
How is suspected misconduct reported?
Cooperation partners can report suspected misconduct via Kojamo’s whistleblowing channel.
As a rule, anyone reporting suspected misconduct via the whistleblowing channel are requested to do so under their own name. However, submitting reports of suspected misconduct can also be done anonymously.
Investigation and responsibilities
All reports are processed carefully and confidentially by persons designated by Kojamo’s legal affairs unit. If necessary, persons who are deemed to have the required knowledge and expertise may take part in the investigation in strict confidence. Reports and data related to the investigation may only be accessed by the persons conducting the investigation and they may only be disclosed to parties that absolutely need them in order to carry out the investigation.
Reports regarding suspicions are subject to the following principles:
- All of the reports are processed confidentially.
- The persons who the suspicions are levelled against or who are linked to them may not review the reports.
- No one who takes part in the investigation may seek to discover the identity of the person who submitted the report in any way, shape or form.
Protecting the person submitting the report
The identity of the person who submitted the report shall be kept secret throughout the entire process, and under no circumstances may it be revealed to the person named in the report or any third parties.
If there is a suspicion of a crime, precautions should be taken for the eventuality that the identity of the person who submitted the report may be revealed during court proceedings. In this case, the person in question should be notified of this.
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).
Reporting the results
The results of investigations are reported to Kojamo’s Audit Committee and the Board of Directors.
The number of reports received through the whistleblowing channel is reported in the company’s Annual Report.
Destruction of information
All of the submitted reports will be destroyed once they are no longer needed for the investigation or procedure. In most cases, they will be destroyed after two months (60 days) from the conclusion of the investigation. 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.
Page updated 4 December 2020