Whistleblow

MSK Group’s Whistleblowing policy and reporting instructions

 

We strive for responsible and ethical operation

An ethical and responsible approach is an integral part of our values and activities. To ensure compliance with the MSK’s Code of Conduct, we offer a whistleblowing channel which is open for all those who wish to inform us of any misconduct. It is vital for us to be able to intervene in any shortcomings and improve our activities.

Whistleblowing channel and its purpose

The whistleblowing channel provides a possibility of reporting any suspected misconduct related to MSK’s activities – anything that is inconsistent with the responsible and ethical principles set out in our Code of Conduct.

You can include your name in your report or send it anonymously. All reports are handled confidentially.

Reporting instructions

1. Introduction

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.

2. When to blow the whistle?

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. 

3. How to blow the whistle?

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. 

4. Legal basis of the reporting instructions

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. 

5. Transfer of personal data to non-EEA parties

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

Procedure for processing reports

Processing persons

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. 

Reception of reports

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. 

Investigation of a report

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. 

Signed reports

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. 

Privacy of a person identified in a report and their access to information

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. 

Removal of data

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. 

 

Please, do not include sensitive personal information about any individual mentioned in your report if it is not necessary for describing your concern.

Whistleblow Report

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