Whistleblowing function
The National Golf & Resort AB has a whistleblower function. Trust and heart. This is a supplement to existing channels for reporting misconduct and irregularities.
In December 2021, a new law came into effect – the so-called Whistleblower Act (SFS 2021:890). The law is a tightening of previous legislation in the area. The purpose of the law is to facilitate and encourage whistleblowing and strengthen the protection of whistleblowers.
Visselblåsning är handlingen att avslöja konfidentiell information om en organisation till personer eller organisationer som är utanför organisationen.
Whistleblowing occurs when employees in a work-related context raise concerns about various types of misconduct within their employer's activities. This can involve phenomena that are illegal, unethical, or directly inappropriate.
The matters reported (whistleblown) by the employee must be of public interest. This means that there must be a greater interest than one's own, i.e. a so-called public interest.
Definition of malpractice
"Misconduct" refers to any serious circumstance that may have a negative impact on The National and/or its operations or the working environment for The National's employees, or any other serious work-related circumstance of public interest to be disclosed.
Irregularities include, but are not limited to, actual or suspected:
- Breaches of laws and regulations (whether civil or criminal);
- breaches of The National's policies, instructions and guidelines;
- mutiny and corruption;
- serious risk to the life or health of individuals (such as, for example, environmental crime or extensive workplace safety deficiencies);
- serious deficiencies in the working environment (such as systematic bullying, discrimination or harassment); and
- behaviour that is incompatible with The National's core values.
Questions solely affecting the relationship between an individual and The National do not generally fall within the definition of misconduct. The National encourages instead that such matters be raised by individuals with their immediate line manager, their manager's manager, or the HR department, depending on the circumstances.
Whistleblower protection
The regulations prohibit employers from punishing whistleblowers in any way. Examples of such retaliation may include bullying, threats, dismissal, redundancy, reassignment, denial of pay rises, spreading rumours, and other attempts to harm and/or affect the whistleblower. The employer may be liable for damages if such measures are implemented as a result of whistleblowing.
Anyone can blow the whistle.
The following categories of people are encouraged to report wrongdoing:
- Employees (including part-time or fixed-term employees)
- Hired personnel (such as consultants or other independent contractors)
- People undertaking internships or volunteer work
- Board members
- Shareholder
- Business partners (e.g. consultants or suppliers). Customers or clients are included integrated discreet business dealings and thus not covered by the Whistleblower Act.
The whistleblower function can also be used by individuals who have not yet entered into an employment relationship with The National, provided that information about misconduct was acquired during the recruitment process or through other negotiations prior to the conclusion of an agreement, as well as individuals who have belonged to one of the above categories of persons and have received or obtained information about misconduct during their time with the organisation.
When reporting misconduct, you must, at the time of reporting, have reasonable grounds to believe that the information about the misconduct is true. However, you are not required to present any evidence or similar. As long as you act in good faith, you will not face any negative consequences, even if the suspicion of misconduct proves to be incorrect after further investigation.
A whistleblowing function should not be used for reporting personal misconduct that only affects the reporter and their work situation. Such misconduct shall be handled internally and is not compatible with the requirement of public interest.
Examples of occasions when the function should not be used are:
- conflicts between the reporter and another employee
- views on leadership
- dissatisfaction with pay setting
Although these conflicts and expressions of dissatisfaction are important to manage, in most cases they are not of public interest and should be handled internally within the respective organisation.
General complaints or feedback on The National
General complaints or feedback regarding The National and its activities should be made via email reception@thenational.se
So you're a whistleblower
The National is keen for any misconduct or irregularities that have occurred within the organisation and which may harm the business or its employees to be identified and investigated as early as possible.
We have chosen for all reports to be received and investigated by the external party Human&heart HR AB and their whistleblowing service ”Trust&heart” to ensure legal certainty. The whistleblowing function is used to report all types of misconduct or irregularities of public interest.
After Human&heart has made an initial assessment of the case, authorised individuals within The National, primarily the HR Manager, can also review the information provided to assess whether further investigation is required.
A report to the whistleblowing function can be made anonymously.
You can submit your application in the following ways:
- Digital registration via Trust&heart: To registration https://visselblasning.trustheart.se/thenational
- Notification by telephone: 08-82 40 00, open 08:00 – 16:00
- Notification by post: Trust&heart, Pelle Bergs backe 3c, 791 50 Falun
You can also meet with an investigator from Human&heart to make a report.
Read through the information about when and how to make a notification, among other things, before you make your notification.
Things to consider before reporting
You are protected against reprisals under current law if you report situations where you have reasonable grounds to believe that information about wrongdoing is true.
You have the legal right to remain anonymous, both to the recipient of your whistleblower report and to your employer. At the same time, we hope you will feel brave enough to be open about who you are so that we can best investigate what has happened.
After you have submitted your report
Once you have submitted your report, a case number will be created and a case handler will be assigned to your case.
- An internal conflict of interest check is carried out to ensure that no case officer has a conflict of interest with what has been reported.
- You will receive an ID and password so that you can follow the status of the case.
- You will receive an update on the status of your case within seven working days. You can opt out of receiving updates in the case description, for example.
- The case officer may wish to contact you. You can have contact without revealing your identity.
If you have chosen to receive follow-up on the case, you can log in with the details you receive when you reported a misconduct. You can then continue to remain anonymous to the case officer, if you wish.
If you have chosen to leave your contact details, the case officer may contact you to ask any questions.
Actions and consequences of the report
If there is reason to believe that misconduct or other serious situations have occurred, an investigation will be decided upon. The investigation involves internal or external investigators delving deeper into the report.
Investigators at Human&heart will provide a recommendation for further handling to the HR Manager. The HR Manager is responsible for The National's internal whistleblowing group, which also includes xxxx and yyyy. The National's internal whistleblowing group will then assess whether the case should be investigated internally or externally. If any of the individuals in the whistleblowing group are subject to the report, they will be excluded from the investigation.
Regardless of the type of investigation carried out, the person who has reported misconduct is protected by confidentiality, as well as against reprisals and obstructive actions.
If your report is deliberately false
If you report situations that you know have not occurred, or if you provide obviously misleading information, you do not have protection under current legislation. You must also not commit any offences when reporting a situation.
Clearly false or misleading reports may be subject to investigation.
Other ways to whistleblow
External channels
As an alternative to using the internal reporting procedure, you can also report misconduct directly to specially selected Swedish authorities (external reporting) without risk of retaliation. Which authority you should report to depends on the nature of the misconduct you are reporting. Reporting should be done using established reporting channels intended for reporting misconduct at the relevant authority.
This is how we process your personal data
All processing of personal data within The Nationals whistleblowing system is carried out in accordance with applicable legislation. Processed personal data is normally deleted within two years after an investigation into a reported irregularity has been concluded.
When assessing and investigating reports received via the whistleblowing service, our partner Human&heart processes personal data as the data controller. You can view their information here privacy policy.
