Whistleblower

WHISTLEBLOWER SYSTEM

ESVAGT has implemented a whistleblower system via use of an online portal. In order to report any suspected misconduct. The whistleblower system can be accessed via the following link:

https://esvagt.whistleblowernetwork.net/

Attorney-at-law, Partner, Mr. Morten Berggreen (Gorrissen Federspiel Law firm) handles all matters reported via whistleblower system and will facilitate investigations and reporting to The ESVAGT Group.

All reports submitted via the whistleblower system will remain confidential and, if desired, anonymous. You can also provide a contact e-mail address in the portal, 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 and report via the portal.

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 Governance Framework 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: Fraud (e.g. financial fraud, document fraud or embezzlement);
  • Serious deficiencies or deliberate error (in e.g. financial reports, statements or in internal accounting controls);
  • Bribery or corruption
  • 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 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 submitting af report via the whistleblower system in accordance with the above, 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 not further action is taken
  • At the latest 5 years after the time of the employee’s departure if disciplinary sanctions are made toward 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

PERSONAL DATA

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

We collect and process personal data about you for the purpose of pursuing a legitimate interest, in ensuring compliance with applicable laws throughout all our operations and facilitating the provision of information by data subjects from us regarding a suspected breach of such compliance and in order to provide a response to the requests made by you which interests in processing the personal data overrides your interests. Under the GDPR this is in accordance with article 6(1) (f).

To comply with a legal requirement. We collect and process personal data about you for the purpose of complying with legal requirement to meet a legal obligation imposed by law, by regulation or by community and/or national rules specific for the reported concern if applicable. Under the GDPR this is in accordance with article 6(1) (c).

You have the right to ask us for information about or access to your personal data. There are some exemptions, which means you may not always receive all the personal data that we process.

You have the right to object to our processing (using) your personal data. This effectively means that you can stop or prevent us from using your personal data. However, it only applies in certain circumstances, and we may not need to stop the processing of your personal data if we can give legitimate reasons to continue using your personal data.

  • The right to erasure . You have the right to ask us to erase your personal data in certain circumstances. You also have the right to ask us to complete personal data you think is incomplete.
  • The right to restriction of processing. Your have the right to ask us to restrict the processing of your personal data in certain circumstances.
  • The right to complaint. If you have any complaints about our processing of your personal data, you may contact the Danish Data Protection Agency.