It is of primary importance for MSK that everyone informs us of any breaches of our Code of Conduct they observe or suspect immediately, so please report any incidents that are in breach of our responsible and ethical principles. We foster an atmosphere of openness and a high ethical standard in everything we do. The purpose of the reporting instructions is to encourage people to report any breaches of the Code of Conduct and to ensure that the investigation process is managed appropriately.

If you observe or suspect any breaches of the Code of Conduct, you should report them immediately. The reports should be made sincerely and with integrity. 

You can fill the form in our webpage “mskgroup.fi/whistleblow” or send us email whistleblow@msk.fi.

If you send your report via webpage-form anonymously we are not able to identify the source of the report. 

These instructions are based on guidelines issued by a working party on the protection of individuals with regard to the processing of personal data referred to in Article 29 of Directive 95/46/EC (Data Protection Directive) and on the EU’s General Data Protection Regulation of May 2018. 

A blanket ban on transferring personal data to non-EEA parties is in force unless specific measures are taken to protect the data. 

All reports will be processed confidentially by the Chairman of the Board and Group CEO. If necessary, other people may also participate in the investigation to ensure that the report is processed appropriately.

Only those processing the reports can access them. Each person processing reports is subject to the duty of non-disclosure, which guarantees confidential processing of reports. While a report is being processed, the responsible person may turn to other persons for information and expertise. This is also done confidentially. 

All reports are taken seriously. Once a report has been received, Chairman of the Group and Group CEO will make a decision to either accept or reject it.  If the report is accepted, the appropriate actions to investigate it will be taken.

The rejecting a report might occur if:

• the report is insincere or malicious
• sufficient information for investigating the matter further is not available; or
• the issue referred to in the report has already been resolved.

If the report concerns matters that are not within the Code of Conduct’s scope of application, Chairman of the Group and Group CEO will take appropriate action to solve the problem.

Any intrusive information of personal nature concerning such areas as health or political, sexual or religious beliefs will not be investigated. 

All accepted reports of suspected misconduct or deviations are investigated thoroughly following these instructions. The appropriate method of investigating the matter will be determined by Chairman of the Group and Group CEO.

All reports will be handled in confidence.

A person whom the suspicion concerns or who has an interest in the matter will not participate in investigating a report.

The processing person or other persons participating in the investigation process will make no attempt to identify the whistle blower unless this person is willing to provide the contact details. 

The whistle blower’s name will only be known to those processing the report if she/he has given the name either in form or by sending the report via email.  If appropriate, a whistle blower referred to in these instructions will be informed of the findings of the investigation concerning their claims, however also taking into account the privacy of the persons against whom the claims were made and other confidentiality issues.

Where the report concerns an offence, the whistle blower will be told that revealing their identity may be necessary in connection with a pre-trial investigation carried out by the authorities and a court hearing.

No-one who reports their suspicions in good faith and participates in investigating potential breaches of our Code of Conduct will incur negative consequences for it. Abuse of the whistleblowing channel, or deliberately reporting false information, is a serious violation that may have further consequences. 

The appropriate data protection legislation will be applied to the rights of the persons whom the reports concern. The interested parties have the right to access the information on them and demand that any information that is incorrect, deficient or outdated be corrected.

All protective measures required to prevent the destroying of evidence and other acts that might harm the processing and investigation of the report will be applied to these rights. 

All personal data contained in the reports will be removed once they are no longer needed for investigation and implementation purposes and, in general, within one month after the conclusion of the investigation. The investigation documents will be anonymized, and name and address data as well as any other information that may allow the identification of the person in question either directly or through other data will be removed.