Selfmade's Whistleblower Policy
Our Whistleblower Policy aims to explain how Selfmade´s Whistleblower Scheme works. Moreover, the policy aims to prevent potential reports from failing to materialise due to uncertainty about the scheme.
What is a whistleblower?
The English term is widely used in other languages, including Danish. A whistleblower is a person who seeks to do the right thing in a difficult situation, in which that person has no option other than anonymously to report issues or even criminal offences, of which the executive management team is either unaware or uninformed. A whistleblower is not a snitch. A whistleblower is a loyal person who wishes to see things done in the right way.
Selfmade’s Whistleblower Scheme
Selfmade has established a Whistleblower Scheme in accordance with EU Directive 2019/1937.
Selfmade’s Whistleblower Scheme will be operated by an external supplier, WhistleSystem ApS, which will provide an anonymous and secure reporting process for the whistleblower. The Whistleblower Scheme shall be used when an employee or other stakeholder is aware of serious misdemeanours or offences in connection with Selfmade´s activities. Examples of circumstances that may be reported via the scheme are described in detail in the “What can be reported?” section of the Whistleblower Policy (see below).
Selfmade encourages anyone who discovers or observes misdemeanours to notify their immediate superior of the occurrence. However, this may not always be the ideal course of action and can mean that the misdemeanour is not reported. For this reason, Selfmade has established a Whistleblower Scheme, so that, if the employee/stakeholder does not wish or is unable to involve his/her immediate superior or wishes to remain anonymous, he/she can still report the misdemeanour.
Anyone who is aware of a misdemeanour or offence, i.e. an internal or external stakeholder, can report via our website Selfmade.com.
The whistleblower may report a person, situation or occurrence. Persons who may be reported are essentially any stakeholder, provided that the report is relevant according the criteria listed in “What can be reported?” (see below) and is related to Selfmade´s corporate activities.
The following officers receive and process reports received in the Whistleblower System (Administration Team):
- Torben Buur, Chairman of the Board, Selfmade A/S
- Jesper Geertsen, CFO, Selfmade A/S
What can be reported?
The Whistleblower Scheme can only be used to report serious misdemeanours or offences. This means that matters regarding cooperation difficulties, dissatisfaction with facilities and dissatisfaction with employment conditions cannot be reported via the Whistleblower Scheme. Matters of these kinds should be reported to your immediate superior.
Examples of matters that may be reported through the Whistleblower Scheme include, but are not limited to, the following:
- Sexual harassment
- Physical violence
- Financial crime
- Work safety
- Consumer protection
- Product safety
- Breach of procurement legislation
- Breach of personal data legislation
- Breach of environmental legislation
- Money laundering
It is Selfmade's policy that we would rather receive one report too many than one too few to ensure that we receive every relevant report. This means that if you are in any doubt whether your report falls within the scope described above, we ask you kindly to submit your report anyway.
How do you report?
The whistleblower can access and submit his report via WhistleSystem as follows:
- Navigate to: https://app.whistlesystem.com or find the link via our website.
- Use the following login information:
- Complete the form with the necessary information so that the administration team can process your report. You report to the system anonymously. This is the only channel where you can report anonymously.
The log-in can be used by any relevant stakeholder, to whom Selfmade has granted access to the Whistleblower Scheme.
Once the report is submitted, it has a unique report ID that must be kept in a safe place. The report ID allows you to log in and reopen the report. You can thereby start an anonymous dialogue, send documentation (if any) and respond to supplementary questions from the administration team. Selfmade encourages the whistleblower to log in regularly after submitting the report in order to respond to any follow-up questions.
Please refer to the system’s user manual for a more detailed review of the reporting process.
How are reports handled?
Selfmade's administration team is responsible for processing the reports.
The process is as follows:
- The administration team notifies the whistleblower within seven days that the report has been received.
- The administration team evaluates and categorises the report and implements a preliminary investigation. In this phase, the administration team may require additional information or documentation from the whistleblower. The team will initiate an anonymous dialogue with the whistleblower via the system.
- The report is processed taking into account the nature of the alleged misdemeanour or offence. The first step is to conduct an internal investigation into the matter. Matters of a particularly serious nature or that mandate police attention will be passed on to the police for further processing.
- The whistleblower is informed of what has been undertaken in the matter within three months of receipt of the report. If the matter takes longer to process, the whistleblower will be regularly updated.
- To ensure compliance with personal data legislation, any personal data related to the report will be processed in accordance with Selfmade's Personal Data Policy.
- When the report is no longer relevant, it will be deleted from the system.
The EU Directive states that a whistleblower must be protected from retaliation as a result of their reporting. No whistleblower should have to worry about future consequences for his or her career and private life as a result of having reported to a whistleblower scheme. If the report falls within the scope of the Whistleblower Directive, Selfmade has no recourse to punish the whistleblower after the report has been lodged.
This shall include the following retaliations:
- Withholding promotion
- Change in working hours and tasks
- Wage cut
- Intimidation, harassment and social exclusion at the workplace
Selfmade's Whistleblower Policy seeks to encourage greater transparency and provide more security for the individual employee or stakeholder.
The system employs a number of safeguards to protect the whistleblower. These include:
- When you send your report, the data is encrypted in accordance with industrial encryption standards through every phase of the process.
- ISO 27001 certified servers in the EU.
- SSL technology that provides an encrypted internet connection between browser and server.
- The system architecture is built on the latest technology and consistently AI monitored, and therefore provides the highest level of security.
- Multifactor authentication feature in the administration team’s login process.
- Redundancy that ensures that no data is lost.
- No IP logging.
If you have questions about Selfmade's Whistleblower Scheme, please contact:
Jesper Geertsen [email protected] (CFO, Selfmade A/S)