At New Wave Group, we aspire to conduct our business ethically and we consider honesty and responsibility important requirements. We promote a business culture where everyone feels safe and are encouraged to act against and report irregularities that occur in our business activities.
The whistleblowing procedure has been implemented to allow employees, shareholders, consultants, suppliers and other stakeholders to report irregularities in a safe and anonymous manner.
If serious irregularities are discovered at an early stage, New Wave Group will be in a better position to prevent risks and limit possible damage. This is to the benefit not only for New Wave Group, but for all our employees, shareholders and stakeholders.
A person reporting a suspected irregularity or violation shall always be entitled to remain anonymous. It is strictly prohibited for our employees to research the identity of a reporting person. Further, it is prohibited for New Wave Group and our employees to hinder or attempt to hinder reporting, as well as to in any way retaliate against a reporting person (or against a relative or other person connected to the reporting person).
When to report?
Irregularities, violations and criminal acts shall primarily be reported internally, e.g. by contacting your supervisor or, if the matter is involving your supervisor, you may contact his/her superior or the HR department.
The whistleblowing procedure shall be used to report serious violations (see further below) when you are not able to use internal reporting functions. This may e.g. be the situation when you cannot openly report the information or if you are an external stakeholder (e.g. a supplier) and do not have an internal contact person you can report to.
What to report?
The following are examples of such serious violations that may be reported:
- Unlawful acts, or acts that are in breach of regulations or regulatory requirements
- Fraud, theft or embezzlement
- Acts that put the safety of others or the environment at risk
- Discrimination or harassment
- Conflicts of interest
- Bribery or corruption
- Unwarranted disclosure of confidential or insider information
- Attempts to hide or conceal any of the above
How to report?
All reports shall be submitted in good faith. You must not be able to submit evidence of the information you report, but you must have reason to believe that the information is correct and you must not knowingly report incorrect or untrue information.
You may report in the following ways:
- Using the online reporting tool IntegrityLog
- Orally, by telephone
- By means of a physical meeting
Reporting by using IntegrityLog
In order to safeguard your anonymity, it is possible for whistleblowers to submit reports by using the online reporting tool IntegrityLog. The service is provided by an external, independent party and 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/. When you have completed your report, you will receive a code that you need to save in order to follow up on your case.
Reports received through the external reporting tool are accessed and handled by authorized personnel only. Upon receipt, the competent staff will decide whether the information received is of such nature that it should be handled within the framework of the whistleblower system and forwarded to the New Wave Group’s Audit Committee.
If you have made a report through the whistleblowing reporting tool and written down the code that you receive when you complete your report, you can follow up your case via https://newwavegroup.integrity.complylog.com/. Log in regularly as investigators may need to ask you additional questions and, in some cases, want to act as quickly as possible.
When you submit a report by using IntegrityLog, you can choose whether you want to provide your contact information or if you want to remain anonymous. Regardless, all reports are taken seriously and are investigated. Contact details will be requested as it may facilitate an investigation if you can be contacted for additional information. However, it is always completely optional to provide this information.
All data communication and storage of personal data is encrypted to prevent them from being distorted or coming to the knowledge of unauthorized persons.
Reporting by telephone
If you want to report an irregularity orally, you may do it by telephone to New Wave Group’s Corporate Legal Counsel Staffan Sandblad, at +46 (0)31 712 89 03.
Reporting by means of a physical meeting
If you want to report an irregularity by means of 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 matter, New Wave Group’s Corporate Legal Counsel will present the matter to the Audit Committee and recommend whether the matter should be further investigated or closed. A decision is taken by the Audit Committee, which reports to the Board of Directors.
You will, within three months from acknowledgement of receipt of your report, be provided feedback to a reasonable extent regarding which measures that have been taken to follow up your report, as well as the reasons for taking the measures.
Processing of personal data
For general information about our processing of personal data, how you contact us etc., go to: https://www.nwg.se/en/privacy-policy/
The legal basis for processing data in relation to whistleblowing matters is that the processing is necessary for compliance with a legal obligation to which we, as controller, are subject.
We only process personal data if it is necessary to follow up and investigate a matter. We may disclose personal data to be able to take action as a result of our investigation of a matter, to use reports as evidence in legal proceedings or if it otherwise is made in compliance with laws or regulations.
Only authorized personnel will have access to personal data related to whistleblowing matters.
Personal data which are manifestly not relevant for the handling of a specific report shall be deleted without undue delay. If we need to follow up a report, the personal data related to the report will be processed for the duration of the matter and will be deleted not later than two years after the matter has been closed.