Whistleblower Policy

ABC Group’s Whistleblower Policy

The following policy has been prepared in collaboration with Deloitte, which also administers ABC Group’s whistleblower scheme. 

1. Purpose

This whistleblower policy applies to ABC Group’s entities, including Concept Living. ABC Group’s whistleblower policy aims to encourage and support employees in reporting serious concerns about illegal or unethical conduct that may harm our organisation, our employees, or the public.

2. Who is covered?

This policy applies to all current and former employees, including full-time, part-time, temporary employees and interns, as well as other persons who are in contact with ABC Group. The protection also applies to those who may be affected by whistleblowing, such as colleagues and relatives, in a work-related context.

3. What is whistleblowing?

Whistleblowing is when an employee reports suspected irregularities, illegal activities, or unethical conduct within the organisation.

4. What can be reported?

Matters relating to breaches of EU law that fall within the scope of the European Parliament and Council Directive on the protection of persons who report breaches of EU law, and/or other serious criminal offences or other serious matters may be reported, provided that these are not specifically exempted from the Act on the Protection of Whistleblowers, cf. Section 1 of the Act.

Under the Act on the Protection of Whistleblowers, breaches are understood as acts or omissions that:

  • Are unlawful or constitute a serious criminal offence or otherwise a serious matter, or
  • Make it possible to circumvent the purpose of the rules that fall within the scope of the Act

Unlawful and serious matters that may be reported via the whistleblower scheme include, for example, information about:

  • Criminal offences
  • Misuse of financial resources, theft, fraud, embezzlement, deception and bribery
  • Sexual harassment and other forms of serious harassment

The above are examples only. If you are in doubt as to whether your observation should be reported, you are encouraged to do so. All enquiries will be handled.

Less serious matters, such as cooperation issues, bullying, or other minor misconduct, must not be reported via the whistleblower scheme, but may be reported through the normal channels of communication. If such matters are reported to the whistleblower scheme, the report will be deleted, and you will not be notified of this.

5. Submit a report

If you have a concern, you must report it electronically via our online reporting system.

6. Protection of whistleblowers

We understand that it can be difficult to report a concern. We will do our best to protect employees who report concerns in good faith from retaliation.

7. Handling of reports

We will acknowledge receipt of a whistleblower report within seven days. We will provide prompt and appropriate feedback on the report during the investigation. We will conclude the investigation and provide final follow-up within 90 days of submission of the report.

8. Confidentiality

We will maintain confidentiality and security in connection with whistleblowing reports and will only share the information on a “need-to-know” basis.

9. Review of the policy

This policy will be reviewed annually to ensure that it remains relevant and effective. Read the full whistleblower policy for ABC Group here.

10. Questions

All questions regarding the whistleblower scheme may be addressed to Lene Facius by telephone on +45 4026 2630 or by email: [email protected].

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