Whistleblowing Channel

Policy

Onitio strive to maintain an open business culture with high ethical standards throughout the organisation. To facilitate the reporting of concerns of any potential illegal action or misconduct, Onitio has made this Whistleblower policy. This policy outlines the procedures for reporting concerns and for investigating whistleblower reports. The success of this policy depends on the willingness of all employees and stakeholders to come forward and report concerns.

Whistleblowing can be done by anyone with a relevant concern. This includes both current and previous employees, contractors, customers, or even bystanders who witness unethical or illegal activities.

Reporting of concerns (“whistleblowing”) is to report any suspected or potential (i) breaches of law, (ii) company policies or (iii) ethical norms that are widely endorsed in society. For instance, actions or omissions that constitutes:

• Danger to life or health
• Danger to the climate or environment
• Corruption or other financial crime
• Abuse of authority
• Unacceptable working environment
• Breach of personal data security
• Bullying, discrimination, or harassment
• Suspicion of actual or potential breaches of law
• Other unacceptable conditions in the company that affect employees, suppliers, customers, the company itself or the general public, or circumstances that may expose the company to significant reputational damage

You have a general duty to report if you are aware of any criminal offences or practices that may endanger someone's life or health, as well as discrimination or harassment in the workplace.

Procedures for whistleblowing

There are four different channels where you can whistleblow.

• You can always report concerns directly to your immediate supervisor, your immediate supervisor’s manager, or the People & Culture department. You can also report to the union representative, safety representative or working environment committee. Concerns about the top management may be reported to Legal Counsel and/or to the Chairman of the Board in Onitio Group AS.
• Concerns can be reported through a dedicated, encrypted, anonymous reporting mechanism established by Onitio Group in cooperation with Advokatfirmaet Wiersholm AS. The whistleblowing channel is provided by an external partner, Whistleblower Software. Reports through this channel will be received by Legal Counsel and Director People & Culture, who will evaluate all submitted reports, including considering and deciding on further follow-up. If these are absent, the report will be forwarded to Advokatfirmaet Wiersholm for an initial assessment. Normally the reports will be investigated and handled by the local People & Culture department in cooperation with Legal Counsel. Read more about the handling of reports below.
• In cases where internal reporting is not possible or practical, whistleblowers may choose to report their concerns to public authorities, such as law enforcement agencies, regulatory bodies, or other appropriate organizations.
• Whistleblowers may also report concern to the general public, for instance through media, including social media. The right to whistleblow to the the general public is conditional on the employee being in good faith with respect to the contents of their report. Furthermore, the concern must be a matter of public interest and the matter must previously have been reported internally and/or externally to public authorities, without the matter being properly assessed, investigated, or no appropriate remedial action was taken. The requirement that a whistleblowing report first shall be made internally and/or externally to public authorities applies unless there is reason to believe that this whistleblowing would not be productive.

Guidelines for reporting

If you are in doubt as to whether you should report a concern, and you for various reasons do not wish to raise the issue with your manager with personnel responsibility, the manager's manager or safety representative in the company, please contact our Director People & Culture Nordics or our Legal Counsel. If you do not want to submit a report in writing you may contact Director People & Culture Nordics or Legal Counsel by phone or request a meeting to report your concern

Concerns regarding your own employment conditions are normally not regarded as whistleblowing. These are, for example: dissatisfaction with wages, workload and distribution of tasks, personnel conflicts, academic disagreement and personal contractual relationships. We ask you to raise such matters with your immediate supervisor, or your immediate supervisor’s manager, so that this can be handled at the right level internally.

Deviations from procedures and errors in our way of work should be reported through IMS. You can find the reporting form on your local Intranet.

When reporting concerns, whistleblowers should provide as much detail as possible, including:

• A clear description of the action or omission.
• Names of individuals involved (if known).
• Dates, times, and locations of the alleged incidents.
• Any supporting documentation, evidence, or witnesses.
• Their own contact information (if they do not wish to remain anonymous).

Whistleblower’s rights

The Company is committed to protecting whistleblowers from any form of retaliation or adverse consequences for reporting in good faith. Whistleblowers who come forward with genuine concerns will not face any discrimination, harassment, or adverse employment actions. Confidentiality will be maintained to the greatest extent possible, and any individual found to engage in retaliation will be subject to disciplinary action.

Retaliation against whistleblowers is strictly prohibited and will be met with disciplinary action, up to and including termination of employment or contract. Any unfavourable action, practice or omission as a consequence of or in response to the whistleblower’s notification would be considered retaliation.

Deliberately and knowingly reporting wrong or misleading information are considered as reporting in bad faith and are not protected by these whistleblower’s rights. Such reporting in bad faith can on the contrary result in disciplinary action up to and including dismissal.

Onitio’s handling of reports

All reports will be promptly and thoroughly investigated. The severity of the reported concern will influence the complexity of the assessment, investigation, and potential remedial action. This is what you need to know about the process:

• All enquiries are taken seriously.
• The person reporting their concerns shall within a reasonable amount of time receive confirmation that their report has been received, with an indication of how things will proceed and how long the process is estimated to take.
• The person about whom the notification is given, shall, as a norm, be informed of the contents of the notification and be given an opportunity to present their side of the matter.
• The employer shall as far as possible process the notification without divulging the identity of the whistleblower to anyone other than those who have a need or right to such knowledge.
• The Personal Data Act's rules on the right to information and access for the whistleblower and the person reported on will be respected during the processing of the case. Persons reported on will have the right to know the identity of the whistleblower, unless there is a basis for exemption under the personal data protection rules.
• The employer shall initiate appropriate investigations and ensure that the matter has been satisfactorily clarified before a decision is made.
• The employer must consider whether measures need to be implemented in order to protect the interests of the parties involved before a conclusion is reached on the matter.
• The process must be documented in writing, and a decision must be made about whether censurable actions or omission have taken place.
• The parties shall be notified of the outcome as soon as possible.

«If appropriate, the employer shall implement remedial actions.»