A whistleblower scheme is an anonymous or non-anonymous possibility to ‘blow the whistle’ if you become aware of or suspect that unlawful activity is taking place at the company.
We’re a responsible organisation with an open corporate culture, in which everyone is free to raise concerns – especially if they become aware of any irregularity or unlawful activity.
Normally, the preferred option would be for you to talk with your manager, your manager's manager or your HR partner. If you feel that you cannot talk with anyone in management or your HR partner, you may report your concern anonymously or otherwise via the DHI Whistleblower Scheme.
Under this scheme, our employees and stakeholders may submit anonymous or non-anonymous reports – made in good faith – of concerns they may have about serious matters. These include matters which may inflict financial losses on us, damage our reputation, or have similar such negative effects.
The purpose of the whistleblower policy is to explain how the Whistleblower Scheme works in order to counteract any potential reluctance to report concerns.
WHO CAN REPORT CONCERNS?
Concerns may be reported by all our employees and by persons who have commercial or professional relationship with us. The latter may include customers, suppliers and external consultants.
WHO MAY CONCERNS BE REPORTED ABOUT?
Concerns may be reported about illegal or damaging activity in which our employees are involved.
ANONYMITY AND IT SECURITY
When reporting a concern, you choose whether you want to report the concern anonymously.
All concerns raised in good faith are protected from any and all harassment or victimisation as a consequence of the report. Anyone who tries to harass or victimise a person who has reported a concern in good faith will be subject to sanctions under employment law.
If a person reporting a concern chooses not to be anonymous, the company will, to the greatest possible extent, treat the report as confidential. If a non-anonymous report of a concern leads to legal proceedings being instituted against the person reported, the person reporting the concern may be summoned as a witness in the proceedings.
WHAT CAN BE REPORTED?
It is the intention that the Whistleblower Scheme only be used to report concerns about serious matters or suspected serious matters. Thus, the concerns raised must involve gross violation of laws, regulations, policies, guidelines and so on, including our guidelines for employee behaviour.
Other matters (such as dissatisfaction with salary conditions, collegial difficulties, violation of smoking policy and so on) should not be reported via the Whistleblower Scheme. These concerns should instead be raised through the normal channels (management or HR).
Serious concerns that may be reported via the Whistleblower Scheme include:
- economic crimes such as embezzlement, bribery, fraud and forgery
- submission of false or misleading information to public authorities
- material breaches of work safety regulations
- material breaches of environmental regulations/environmental pollution
- physical violence and sexual offences
- irregularities related to accounting and auditing
The list above should be seen as examples only. If you are in doubt as to whether or not to report your observations, you should report them. Your help is very important and all reported concerns will be answered and dealt with. If you file a non-anonymous report that cannot be dealt with under the Whistleblower Scheme, we will inform you and ask you to go through the normal channels instead (management or HR).
WHO WILL DEAL WITH REPORTED CONCERNS?
Any concern reported will be dealt with by representatives from our Board of Directors, who are independent of the daily management of DHI. They will initiate an investigation of the matter reported. The DHI Audit Committee will monitor and deal with any reported concerns.
HOW WILL REPORTED CONCERNS BE DEALT WITH?
When a report is received, an initial investigation will be conducted into the matter.
If the concern turns out to be unfounded, it’ll be rejected and, at the end of investigation, the reporter will be informed of the case closure.
If the conclusion of the initial investigation warrants further examination, it’ll be subjected to a more detailed investigation. The matter will be dealt with in-house by the DHI Audit committee, and it may impact the employment of the person reported. After the conclusion of the investigation, the matter will be kept on the personnel file of the person in question, for up to five years.
The matter may also be referred to the police for further investigation. The person reported may face a fine or imprisonment. When the police (and possibly the courts) have completed their processing of the matter, the case will be deleted from the system.
It’s important that the system is not used to make false accusations, raising suspicions against innocent people. All reported concerns must therefore be made in good faith. If a concern is unfounded or reported in bad faith and the report turns out to be the result of negative personal feelings, vindictiveness and so on, then it may have consequences for the employment of the reporter, if and when he or she is identified.
HOW IS A CONCERN REPORTED?
Concerns can be reported via the DHI Corporate Whistleblower Portal. Concerns cannot be raised in any other way (like sending an e-mail to the person responsible for the Whistleblower Scheme), as the information is confidential information which should not be sent unencrypted over the open Internet.
INFORMATION ABOUT A REGISTERED CONCERN FOR THE PERSON REPORTED
We’re obliged to inform the person concerned about the report. However, we may refrain from complying with this obligation if material interests make it inadvisable. We’ll determine when the information can be provided without consequences to the investigation and the collection of evidence.
The identity of the person reporting the concern will not be disclosed, even if the reporter has chosen not to be anonymous.
When a report is made, we will process the personal data regarding the data subjects that are part of the report (i.e. the sender of the report, the reported person and other involved third parties) in order to handle and investigate the report.
If you report a suspected violation, such report will to the widest extent possible remain confidential and, at your choice, anonymous. When filing a report, you have the possibility of creating a password, allowing for confidential and anonymous communication regarding the reported matter.
Types of personal data
We may process the following personal data about the reported person:
- Name, position, department, contact information and reported information
- Description of the alleged violation
The following personal data may be processed on third parties mentioned in the report:
- Name, position, department, contact information and other reported information
Your personal data, if you provide any, will be processed for the following purposes:
- Administration of the Whistleblower scheme
- Handling reported incidents, including clarification of potential criminal matters
Basis for processing
DHI processes personal data on the basis set out below.
- Legitimate interests: We may process your personal data on the basis of our legitimate interests in investigating reported incidents (Article 6(1)(f) of the General Data Protection Regulation (‘GDPR’)).
- Legal obligation: As of 17 December 2021, it is mandatory for DHI to have a whistleblower scheme, and accordingly, the personal data will be processed in order to fulfil our legal obligation (Article 6(1)(c) of the GDPR).
If the report is manifestly baseless, it will be deleted immediately. For other reports, DHI will retain the personal data for as long as it is necessary in order to address the specific reports.