Whistleblowing
New Wave Group strives to conduct our business ethically, with high standards of honesty and responsibility. We promote a business culture where everyone feels safe and encouraged to act against and report misconduct in our operations.
The whistleblowing function has been implemented to enable employees, shareholders, consultants, suppliers, and other stakeholders to safely and anonymously report possible misconduct.
If serious misconduct can be detected early, New Wave Group prevent risks and limit possible damage. This benefits not only New Wave Group but also all our employees, shareholders, and stakeholders.
Anyone reporting suspected misconduct has the right to remain anonymous. It is strictly forbidden for our employees to research the identity of a person who has submitted a report. It is also forbidden for New Wave Group and our employees to obstruct or attempt to obstruct reporting, as well as to in any way retaliate against the person reporting (or against their relatives or others connected to the person reporting).
When to report?
If you are an employee, misconduct, irregularities, and criminal acts shall primarily be reported internally, e.g., by contacting your immediate supervisor. If the matter involves your supervisor, you may contact his/her superior or the company’s HR department.
The whistleblowing function shall be used to report more serious matters (see further below) when you cannot use the internal reporting channels. This may be, for example, if you feel that you cannot be open with the information or if you are an external stakeholder (such as a supplier) and do not have an internal contact you can report to.
What to Report?
Below are examples of serious violations that may be reported:
- Actions that are illegal or violate regulations or regulatory requirements
- Fraud, theft, or embezzlement
- Actions that endanger other’s safety, health, or the environment
- Discrimination or harassment
- Conflicts of interest
- Bribery or corruption
- Breaches of confidentiality or insider trading rules
- Attempts to hide or conceal any of the above
How to Report?
The information you provide shall be reported in good faith. You do not need to have evidence for what you report, but you must have reason to believe that the information is correct and you must not knowingly report false information.
You may report in the following ways:
- Using the online reporting tool IntegrityLog
- Orally, by phone
- At a physical meeting
Reporting Through IntegrityLog
To ensure your anonymity, whistleblowers can submit reports through the external online system IntegrityLog. The reporting channel is encrypted and password-protected. You must never disclose your identity unless you choose to do it.
To make your report, go to https://newwavegroup.integrity.complylog.com/. Once you have completed your report, you will receive a code that you need to save in order to follow up on your case.
Reports submitted through the external reporting tool are accessed and handled by authorized personnel only. The authorized personnel will determine if the received information is of such nature that it should be handled within the framework of the whistleblower system and forwarded to New Wave Group’s Audit Committee.
If you have made a report through IntegrityLog, you can follow your case via https://newwavegroup.integrity.complylog.com/ by logging in with the code you receive when you make the report. Log in regularly as investigators may need to ask you additional questions and, in some cases, may want to act as quickly as possible.
As a reporter via the system, you can choose whether you want to provide your contact details or if you want to remain anonymous. Regardless, all reports are taken seriously and are investigated. Contact details will be requested as it can sometimes facilitate an investigation if you can be contacted to provide additional information. However, it is always entirely voluntary to provide these details.
No IP addresses are registered, and the system does not use cookies. If you use a computer that is connected to New Wave Group’s network, it may appear in the Internet log that you have visited the page where the report is made. If you do not want this to be visible, use a computer that is not connected to New Wave Group’s network.
All data communication and storage of personal data are encrypted to prevent them from being altered or accessed by unauthorized persons.
Reporting by Phone
If you want to report misconduct orally, you can do so by phone to New Wave Group’s General Counsel Staffan Sandblad, at +46 (0)31 712 89 03.
Reporting at a Physical Meeting
If you want to report misconduct at a physical meeting, please contact New Wave Group through any of the channels set out above.
What Happens When You Have Made a Report?
When we have received and verified a case, New Wave Group’s General Counsel will present the matter to the Audit Committee and recommend whether to further investigate or close the case. A decision is taken by the Audit Committee, which reports to the Board of Directors.
You will also, within three months from the confirmation that we have received your report, receive feedback to a reasonable extent on the actions taken to in response to the report and the reasons for these actions.
Processing of Personal Data
For general information on how we process personal data and how to contact us etc., see: https://www.nwg.se/en/privacy-policy/
The legal basis for processing data in connection with whistleblowing cases is that the processing is necessary to fulfill a legal obligation that rests on us as the data controller.
We only process personal data if it is necessary to follow up on a case. We may disclose data to be able to take action based on our investigation of a case, to use reports as evidence in legal proceedings, or if it otherwise is made in compliance with laws or regulations.
Only authorized persons have access to personal data related to whistleblowing cases.
Personal data that is clearly not relevant to the handling of a report is deleted. If we need to follow up on a case, personal data related to the report will be processed as long as the case is ongoing and be deleted no later than two years after the case has been closed.