WHISTLEBLOWER FUNCTION

Whistleblower Function 

The Whistleblower Function exists to strengthen protection for people who report misconduct in the workplace. 

Misconduct refers to all types of negligence or irregularities, regardless of whether they are due to deliberate action or negligence. Various types of negligence or irregularities that have not yet occurred, but are highly likely to occur, can also be a misconduct. Attempts to conceal misconduct can in themselves constitute misconduct. The misconduct does not have to be current or ongoing.

For there to be a public interest, the circumstances must be serious, concern a group that can be described as the public and there must be a legitimate interest in the misconduct coming to light.

The misconduct must also be of such a nature that the whistleblower, at the time of reporting, had reasonable grounds to assume that the information about the misconduct was true.

A whistleblowing may lead to the following measures:

Investigated by management, the board, internal audit or HR as a disciplinary matter
Remitted to the Police Authority or another authority
Investigated by independent auditors
Become the subject of an independent investigation
Matters that are not deemed to be of a whistleblowing nature will be reviewed but will not be handled according to the Whistleblower Function but according to other internal procedures. In cases where the matter is clearly not deemed to constitute a whistleblower matter, the reporting person will receive this confirmed in a feedback from the authorized person/unit in the portal. In other cases, Lykke takes the measures deemed appropriate, which may be a continued in-depth investigation. If a crime is suspected, this may be reported to the police authority. 

Protection
A person who discloses an irregularity will be protected if the reporting person discloses the information in good faith, with good intentions and assumes that the information is substantially true. If it later turns out, for example after an investigation, that the information was not correct, this is accepted as long as the person acted in good faith. The reporting person will not be subject to any retaliation (termination, reassignment, dismissal, ostracism, harassment and reduced pay as punishment) or disciplinary action from Lykke as a result of reporting an irregularity. To the extent possible, evidence that can be traced back to the reporting person will be kept confidential. Lykke does not tolerate any person who has reported an irregularity being subjected to adverse treatment, discrimination or other forms of retaliation. Reporting false, malicious or unfounded allegations means that the reporting person is not covered by the above protection and such reporting may lead to employment law consequences. If the whistleblower has himself/herself been involved in irregularities, the whistleblower is not protected from disciplinary or legal action as a result of making a report.

If you want to blow the whistle and report serious risks, violations, irregularities, crimes or misconduct, you can do so here.