WHISTLEBLOWER SYSTEM

ESVAGT is currently in the process of implementing a Whistleblower system. Until the system is fully implemented, ESVAGT employees and external stakeholders have the possibility to report suspected misconduct to attorney-at-law, Partner Jens V. Mathiasen (Gorrissen Lawfirm) by telephone at
+45 3341 4141 or by e-mail at JVM@gorrissenfederspiel.com.

Jens V. Mathiasen will consequently decide on appropriate measures for the specific reporting.

 

Reporting will remain confidential and, if desired, anonymous. You should in any case provide a contact e-mail address, as the investigating person may need to contact you for further details on the incident to be able to handle the case properly.

If you are an employee of ESVAGT we encourage you to consider raising the concern via management, legal or HR personnel. If this is not an option, you may use the option provided above.

 

What may be reported:

Serious and sensitive concerns that could have an adverse impact on the operations and performance of ESVAGT or which may have a significant effect on a person’s life or health may be reported. Such concerns could include, without limitation, concerns regarding:

 

  • Serious breaches of safety related policies as specified in the ESVAGT Integrated Management System
  • Other issues posing a serious threat to life or health of individuals
  • Violence, sexual assaults and serious discrimination by or against employees
  • Pollution and breaches of environmental laws and rules
  • Severe breaches of the ESVAGT Code of Conduct;
  • Breach of the competition law compliance policy and laws (e.g. price fixing);
  • Other severe irregularities of a general and/or operational nature;
  • Accounting or auditing matters or irregularities of a financial nature, legal and/or ethical nature, such as;

(i) fraud (e.g. financial fraud, document fraud or embezzlement);
(ii) serious deficiencies or deliberate error (in e.g. financial reports, statements or in internal accounting controls)
(iii) bribery or corruption
(iiii) providing false information to authorities.

 

What may not be reported:

Issues not listed above or of a less severe nature may not be handled as per above. Such issues include for example bullying, cooperation problems, incompetence, absence, breach of policies such as drugs or alcohol (other than serious breaches of safety related policies), e-mail and internet policy, etc. 

When a reporting is within above scope you are protected from any kind of retaliation or discriminatory or disciplinary action as a result thereof, including termination of employment, demotion, suspension, threats or any other kind of harassment. However, such protection does not apply if the system is abused, e.g. if you intentionally make a false allegation.

 

Subject to other requirements under local law, the report and collected information will be deleted:

 

  • immediately if the report is outside the scope or is manifestly unfounded, or if no internal action is made in relation to the concern
  • right after the closing of the case by the authorities if a report is filed with the police or other relevant authorities.
  • 2 months after the investigation has been completed if no further action is taken
  • at the latest 5 years after the time of the employee’s departure if disciplinary sanctions are made towards the reported employee based on the collected information, or other reasons for it being factual and necessary to continue storing the information, the collected information will be stored in the personnel folder in question.

The data controller of data processed under this reporting is ESVAGT A/S, Dokvej 4, DK-6700 Esbjerg.