Report Misconduct
Wellstreet Whistleblower Policy
Last updated 2023-01-01
Concepts & Definitions
Corruption: exploiting a public position for personal or others gain
Improprieties: undesirable behaviour or actions by employees that affect our business or reputation.
Why do we need a whistleblower function?
Public organisations and private companies with at least 50 employees must have a whistleblower policy and setup for anonymous, verbal, and personal reporting, following Swedish legislation. We have introduced a whistleblower function based on the EU Whistleblower Directive. This is Swedish law through the (2021:890) act. The law aims to protect those who report through a whistleblower channel from any sort of retaliation.
A whistleblower should be able to report matters anonymously, verbally, or in person, primarily to report potential violations of legislation, irregularities, corruption, or improprieties, in order to improve organisations and provide insights to selected management. Our organisation does not have the right to track or investigate who the whistleblower is, in case the whistleblower chooses to remain anonymous.
What does "Whistleblowing" mean?
Whistleblowing means reporting and informing about suspicions, ongoing crimes, or corruption. It can also include harassment of different forms.
Who can use our whistleblower function?
Anyone can point out faults and shortcomings.
Who should the information concern?
The misconduct about potential violations of legislation, irregularities, or improprieties, i.e harassment, suspicions, ongoing crimes, or corruption should concern a person that work, have worked, or wanted to work with us or any of portfolio companies. This includes consultants, collaborators, suppliers, volunteers, mentors, interns, and potential personnel.
What is a whistleblower report and what protection does it provide?
To receive whistleblower protection, there must be an interest in the information. This may relate to things that have occurred, are happening, or will happen. The protection you receive is that you will not be subjected to retaliation. IF you choose to remain anonymous, there is also a ban on us from investigating who you are in any way.
Important to consider when whistleblowing
You can whistleblow on events or actions, whether intentional, ignored, or accidental. You also have the right to report on accidents. As a whistleblower, you do not need to provide evidence, but there should be objective parts that can be further investigated so that we have a chance to act in the best possible way. That is, information that enables us to investigate whether your report is true or not. It is not a requirement, but when you whistleblow, it is good if you give us as much information as you can, and then we will act in the best way based on your report.
What happens after your whistleblowing report?
When you whistleblow, the matter is brought to us and then we will investigate its legitimacy, reasonableness, and seriousness. We may receive, investigate, and act using internal staff (selected group) or with the help of an external partner (independent consultant) to ensure that your whistleblowing is handled as well as possible.
What you must not do
You must not report on state secrets or share information regarding national security. You must also not knowingly make false information public or defame anyone, as it is a criminal act.
.png)
