Whistleblowing.

When to use.

The whistleblowing service is intended for reporting serious concerns, such as: 

• accounting irregularities, internal control issues or auditing concerns 

• bribery, corruption, financial crime 

• money laundering and terrorist financing

• serious breaches of environmental regulations 

• major deficiencies in workplace safety 

• severe forms of discrimination, harassment, or other unethical behaviour 

• any other misconduct that may significantly harm individuals, ELMC, society, or the environment. 

Reports related to general dissatisfaction at work, conflicts, salary matters, or day-to-day HR issues should be handled with a manager or HR, not through the whistleblowing channel. 

You do not need to have proof of your suspicion. However, all reports must be made in good faith. Deliberate misuse of the service or knowingly providing false information is strictly prohibited.

The investigation process.

Whistleblowing Team 

Only designated and authorized members of ELMC’s whistleblowing team have access to reports. They are bound by confidentiality, and all actions are logged. Additional experts may be involved when necessary, and they are also bound to confidentiality.

Receiving and assessing a message 

After receiving a report, the whistleblowing team decides whether it falls within the scope of these guidelines. A report may be declined if:

• it does not concern reportable misconduct 

• it was not made in good faith or appears malicious 

• there is insufficient information to investigate 

• the matter has already been resolved 

If a report concern matters outside these guidelines, the whistleblowing team will take appropriate steps to route the issue to the correct channel. 

Receipt of the report will be acknowledged within 7 days. Feedback will be provided within 3 months, unless the case is complex and requires extended handling. 

Do not include unnecessary sensitive personal information in your report.

Conducting the investigation.

All accepted reports are handled seriously and confidentially. 

• No one involved in the investigation will attempt to identify an anonymous whistleblower.

• Additional questions may be asked through the anonymous channel if needed.

• No individual who may be involved in the alleged misconduct will participate in the investigation.

• The whistleblowing team decides if and when a case should be escalated.

Protection of non-anonymous whistleblowers 

Anyone reporting genuine concerns in good faith will not face dismissal, retaliation, discrimination, or any personal disadvantage, even if the suspicion later proves to be unfounded.

Subject to confidentiality and privacy considerations, non-anonymous whistleblowers will be informed of the investigation outcome.

If a case involves criminal offences, the whistleblower may need to disclose their identity to authorities during legal proceedings.

Processing of personal data.

The whistleblowing service may process personal data about the person mentioned in the report, the reporter (if not anonymous), and any other individuals involved. Data is processed solely for investigating alleged misconduct and ensuring compliance with legal and ethical requirements. 

This process is based on ELMC’s legitimate interest in preventing ethical and legal risks. 

Personal data is accessible only to authorized individuals and handled confidentially. 

You may exercise your rights (access, rectification, objection, restriction) according to applicable data protection laws, subject to limitations necessary to preserve the investigation’s integrity. 

Data deletion 

When the report is handled, all history will be saved with the company for two (2) years, thereafter deleted.