Visselblåsarfunktion

Whistleblowing Function

The National Golf & Resort AB has a whistleblowing function through Trust & Heart. This serves as a complement to existing channels for reporting misconduct and irregularities.

In December 2021, a new law – the Whistleblower Act (SFS 2021:890) – came into effect. The law strengthens previous legislation in this area. Its purpose is to facilitate and encourage whistleblowing while enhancing protection for whistleblowers.

What is whistleblowing?

Whistleblowing occurs when employees, in a work-related context, raise concerns about various types of misconduct within their employer’s operations. This may include behavior that is illegal, unethical, or otherwise inappropriate.

Reports (whistleblowing) must be of public interest, meaning that the matter goes beyond personal concerns and is relevant to a wider societal or organizational interest.

Definition of misconduct

Misconduct refers to any serious circumstance that may negatively impact The National and/or its operations, the working environment for The National’s employees, or any other significant work-related issue that is in the public interest to report.

Misconduct includes, but is not limited to, actual or suspected:

Violations of laws and regulations (civil or criminal);
Violations of The National’s policies, instructions, and guidelines;
Bribery and corruption;
Serious risks to individuals’ life or health (for example, environmental crimes or major safety breaches in the workplace);
Serious deficiencies in the work environment (such as systematic bullying, discrimination, or harassment); and
Other behavior inconsistent with The National’s core values.

Issues that exclusively concern the relationship between an individual and The National generally do not fall under the definition of misconduct. Instead, The National encourages employees to address such matters directly with their immediate manager, the manager’s superior, or the HR department, depending on the circumstances.

Protection for whistleblowers

The legislation prohibits employers from retaliating against anyone who has reported misconduct. Examples of reprisals include bullying, threats, dismissal, termination, reassignment, withholding of salary increases, spreading rumors, or any other actions intended to harm or influence the whistleblower. Employers may be held liable for damages if such actions are taken as a result of whistleblowing.

Who Can Blow the Whistle?

The following categories of people are encouraged to report misconduct:

Employees (including part-time or temporary staff)
Hired personnel (such as consultants or other independent contractors)
Individuals performing internships or volunteer work
Board members
Shareholders
Business partners (e.g., consultants or suppliers). Customers or clients are not considered business partnersand are therefore not covered by the Whistleblower Act.

The whistleblowing function may also be used by individuals who have not yet entered into a work-related relationship with The National, provided that the information on misconduct was obtained during the recruitment process or through other negotiations prior to entering into an agreement. It also applies to individuals who previously belonged to any of the categories above and received or obtained information about misconduct during their time with the organization.

When reporting misconduct, you must have reasonable grounds to believe that the information is true at the time of reporting. However, you are not required to provide proof. As long as you act in good faith, you will not face negative consequences even if further investigation shows that the suspicion of misconduct was incorrect.

What whistleblowing should not be used for

The whistleblowing function should not be used to report personal grievances that only affect the reporter and their working situation. Such matters are handled internally and are not considered of public interest.

Examples of situations where the whistleblowing function should not be used include:

Conflicts between the reporter and another employee
Criticism of leadership
Dissatisfaction with salary decisions

While these conflicts and expressions of dissatisfaction are important to address, they are usually not of public interestand should be handled internally within the relevant part of the organization.

General complaints or feedback about The National
General complaints or feedback regarding The National and its operations should be sent via email to reception@thenational.se.

How to Blow the Whistle

The National wants to ensure that misconduct or irregularities that occur within the organization, and which may harm the business or its employees, are reported and investigated as early as possible.

All reports are received and investigated by the external provider Human&heart HR AB through their whistleblowing service Trust&heart, ensuring legal protection and impartial handling. The whistleblowing function is used to report all types of misconduct or irregularities of public interest.

After an initial assessment by Human&heart, relevant individuals within The National, primarily the HR Manager, may access the information provided to determine whether further investigation is necessary.

How to Make a Report

Reports to the whistleblowing function can be made anonymously. You can submit a report in the following ways:

Online via Trust&heart: https://visselblasning.trustheart.se/thenational
By phone: 08-82 40 00, open 08:00 – 16:00
By mail: Trust&heart, Pelle Bergs backe 3c, 791 50 Falun
In person: You can meet with an investigator from Human&heart to submit a report.

Please read all information about when and how to make a report before submitting your whistleblowing case.

Things to Consider Before Making a Report

You are protected against retaliation under applicable law if you report situations where you have reasonable grounds to believe that the information regarding misconduct is truthful.

By law, you have the right to remain anonymous both to the person receiving your whistleblowing report and to your employer. At the same time, we encourage you to be open about your identity so that we can investigate the matter in the best possible way.

After Submitting Your Report

When you submit a report, a case number is created and a case handler is assigned.
An internal conflict-of-interest check is conducted to ensure that no handler has a personal interest in the reported matter.
You will receive an ID and password to track the status of your case.
You will receive a follow-up on the status of your case within seven business days. You may choose to opt out of receiving updates in the case description if you wish.
The case handler may want to contact you. Communication can occur without revealing your identity.
If you have opted to receive updates, you can log in with the credentials provided at the time of your report. You may continue to remain anonymous toward the case handler.
If you have provided contact information, the case handler may reach out to ask questions.

Actions and Consequences of a Report

If there is reason to believe that misconduct or other serious situations have occurred, a formal investigation is initiated. This involves internal or external investigators examining the report in detail.

Investigators from Human&heart provide recommendations 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 internal whistleblowing group will then decide whether the case should be investigated internally or externally. If any member of the whistleblowing group is involved in the report, they are excluded from the investigation.

Regardless of the type of investigation, the person reporting misconduct is protected by confidentiality and safeguarded against retaliation or obstructive actions.

If Your Report is Deliberately False

If you report situations you know did not occur, or provide clearly misleading information, you are not protected under applicable law. You must also not commit any criminal act while reporting a situation.

Intentionally false or misleading reports may be subject to investigation.

Other Ways to Blow the Whistle

External Channels
As an alternative to using the internal reporting procedure, you may also report misconduct directly to certain designated Swedish authorities (external reporting) without risk of retaliation. The appropriate authority depends on the nature of the misconduct being reported. Reports should be made using the established reporting channels provided by the relevant authority.

How We Handle Your Personal Data

All processing of personal data within The National’s whistleblowing system is carried out in accordance with applicable legislation. Personal data is normally deleted within two years after an investigation into a reported misconduct case is completed.

When assessing and investigating reports through the whistleblowing service, our partner Human&heart processes personal data as the data controller. You can read their privacy policy here.

Whistleblowing Function