- What is the Whistleblower Line?
As of September 1, 2024, the Act on Protection of Persons Who Report Work-Related Breaches of European Union Law (hereinafter “Whistleblower Act“) entered into force. The law establishes the legal basis for reporting violations of European Union law discovered during work activities and provides protection for the whistleblower. The aim of the law is to ensure protection for whistleblowers who report violations of European Union law discovered during work activities.
The Nordecon Group has created a whistleblower line on the Nordecon AS website that complies with the requirements of the Whistleblower Act. The whistleblower line is designed so that all persons mentioned in section 3 of the Whistleblower Act can anonymously report any breaches listed in section 2(1) of the Whistleblower Act.
- Why is it important to report?
To help the Nordecon Group detect all breaches of European Union law discovered in the course of work activities, including suspicions of fraud and corruption, as early as possible. This allows the Nordecon Group to deal with them quickly and effectively within the group or organization.
Reporting helps to reduce the risks of serious and more socially damaging violations, solve potential problems at an early stage, and prevent violations and the time required to resolve them.
- Who is protected as a whistleblower?
Whistleblower protection is granted to all individuals listed in section 3(1) of the Whistleblower Act who have a work-related connection with a Nordecon Group company.
- What kind of incidents should be reported through the whistleblowier line?
Incidents to be reported through the whistleblower line are those listed in section 2(1) of the Whistleblower Act, such as (non-exhaustive list):
- you are discriminated against;
- workplace bullying occurs;
- you are pressured to do something that is not in line with your own beliefs or ethical business practices;
- a Nordecon Group employee or partner has violated the law or ethical business practices;
- violations related to public procurements;
- environmental protection, occupational safety, fraud, corruption violations, etc.
The information provided does not need to be proven, but the whistleblower must confirm that the information they submitted is, to the best of their knowledge, true and accurate, and the whistleblower understands that the accuracy of the information provided is important for the further procedure. The whistleblower is aware that providing false information may lead to liability and legal consequences. Therefore, the whistleblower confirms in good faith and to the best of their knowledge that all provided information is correct.
If necessary, the independent auditing firm Ernst & Young Baltic AS will forward the information about breach to the competent authority for processing.
- What incidents should be reported through other channels?
The Nordecon Group company’s employees and with topics related to the workplace, it is also advised to use the whistleblower line, thus the anonymity of the employee is also guaranteed.
Warranty issues and defects require a more detailed process and generally do not fall under the topics covered by the Whistleblower Act. Therefore, for warranty issues and defects, please contact the developer of the building or structure, write to the email address provided in the handover instructions for the building, structure, or apartment ownership, or to Nordecon AS’s general email nordecon@nordecon.com.
- Is the whistleblowing line secure and anonymous?
Nordecon Group companies fulfil all obligations arising from the Whistleblower Act regarding the whistleblower line. The whistleblower line management services are provided by the independent auditing firm Ernst & Young Baltic AS. All reports submitted through the whistleblower line reach Ernst & Young Baltic AS, which forwards them anonymously to the Nordecon Group company. The whistleblower’s full anonymity is guaranteed when using the whistleblower line.
- Who handles the reports?
Reports of breaches are received and processed by the independent auditing firm Ernst & Young Baltic AS, which forwards the anonymous report to the Nordecon Group company. If necessary, specialists and other competent persons are involved in the process, or the report is forwarded for further processing to the competent person or institution, all of whom fulfil the obligations arising from the Whistleblower Act, including ensuring the whistleblower’s confidentiality. The whistleblower’s anonymity is guaranteed before the Nordecon Group company.
The independent auditing firm Ernst & Young Baltic AS provides feedback to the whistleblower on the receipt of the report, the progress of the procedure, and the application of follow-up measures. Confirmation and feedback are not provided if the whistleblower has explicitly prohibited sending feedback or if there is reason to believe that it would endanger the whistleblower’s confidentiality.
The independent auditing firm Ernst & Young Baltic AS sends a confirmation of receipt of the breach report to the whistleblower within 7 days after receiving the report. If the report is not within the scope of the Whistleblower Act and the protection provided to the whistleblower does not apply, Ernst & Young Baltic AS will inform the person who submitted the breach report.
If Ernst & Young Baltic AS is not competent to process the report, Ernst & Young Baltic AS will forward the report to the competent authority at the earliest opportunity and inform the whistleblower of this.
The independent auditing firm Ernst & Young Baltic AS provides feedback to the whistleblower on the implementation of follow-up measures and the final outcome of the breach procedure as soon as possible, but no later than three months after receiving the breach report.
Breach reports are kept for three years from the date feedback is provided to the whistleblower.
