Novafos A/S Whistleblower Platform is established based on the principles of openness and responsibility, and it is to be a supplement to the internal dialogue in Novafos A/S.
The purpose of the Whistleblower Platform is to ensure an anonymous, confidential, and independent channel for reporting of matters that are unsuitable to be directly handled by the regular channels.
You may use the Whistleblower Platform to report any irregular, unethical behaviour, violation of the law or reasonable suspicion. You can also report violations of internal guidelines.
As an example, you may report about the following subjects to the Whistleblower Platform:
Submission of incorrect or misleading information to public authorities
Physical violence or sexual abuse
Violation of occupational safety
Threats to environmental health and safety
When you report through the Whistleblower Platform, you are assured that all cases are screened and handled by Lund Elmer Sandager Law Firm. Lund Elmer Sandager is impartial and has great experience in handling whistleblower reports.
All reports are handled strictly confidentially. As a whistleblower you can either choose to be anonymous or confidential. If you choose confidential, you should state your contact information (name, e-mail, telephone number) in connection with your report and only Lund Elmer Sandager will be able to see this information. The contact information is not passed on to Novafos A/S. You also have the choice of being anonymous in your reporting. When you are anonymous, we do not have the opportunity to identify you, and it is more difficult for us to communicate with you and ask clarifying questions. The communication between you and Lund Elmer Sandager is in every way secure and will happen mainly through the Whistleblower Platform. You can find more information about the case processing and protection of your personal information under the menu option "Privacy Policy". In the Whistleblower Policy, you can read more about usage of the Whistleblower Platform. If you have any questions, please see the most common questions under the menu option "FAQ".
The Whistleblower Platform is not to be used for false accusations or harassment of persons, and no intentional/false information may be reported at all. Anyone who reports through the Whistleblower Platform in good faith is protected from reprisals. If you want to make an external report of a matter, it can be done to the relevant authority. If you have any questions, you can contact Lund Elmer Sandager at mail whistleblower@les.dk.
Thank you for using the Whistleblower Platform and contributing to openness in the company!
Whistleblower FAQ
Here you may find answers to frequently asked questions about Novafos A/S Whistleblower Platform.
Why?
To comply with applicable law and to ensure an open culture where everyone has a confidential channel to report any suspicion of irregularities or illegalities that may have economic and reputational significance for us.
All matters reported through the Whistleblower Platform are processed by Lund Elmer Sandager, which is a law firm that has extensive experience in handling Whistleblower cases. Novafos A/S will only be involved in the case when Lund Elmer Sandager assesses that it is relevant and can be done without compromising an effective and confidential processing of your report.
Cases of violation or breaches of the law or internal policies and guidelines. This may, for example, be a violation of the rules on open procedure, consumer protection, GDPR, money laundering, working environment, tax evasion or similar. The Whistleblower scheme cannot be used to report pure HR matters, such as dissatisfaction with a salary negotiation or cooperation difficulties.
When making a report, please provide as much information as possible. Please be thorough in your description and give concrete examples of dates or people involved. Even the smallest details which may seem irrelevant could be important in the case processing, thus do not leave any details out. Further, you are also encouraged to describe how you experienced the situation when it happened.
How?
You can report through the Whistleblower Platform 24 hours a day, 7 days a week. The Whistleblower Platform is available on smartphones, tablets and computers.
To ensure a high level of security, you cannot report to the Whistleblower Platform by sending an e-mail. Thus, please fill out the information in the relevant boxes in the Whistleblower Platform. If you make a report while you are on the company network, it will be possible for us to see that you have accessed the website, but not what you have written and how far you have come in the reporting process. To avoid this, you can access the Whistleblower Platform outside the company network, e.g. at home or through your smartphone on the mobile network.
Once you have made a report, you will be provided with a code. You should write it down and store it in a safe place. If you provided your e-mail address, you will receive a confirmation of your report. Please note that the confirmation e-mail does not contain the code due to security considerations, so you must write down the code when you report a case.
Lund Elmer Sandager will then assess your report and begin processing the case. On the Whistleblower Platform, Lund Elmer Sandager is able to contact you and you can likewise contact the lawyer who is handling your case or provide follow up information. Lund Elmer Sandager can, for example, ask for additional information from you or ask you further questions. As such, it is important - especially if you have reported anonymously - that you log in once in a while and monitor your case through the code you have received. When Lund Elmer Sandager has collected enough information, a contact person from Novafos A/S will be involved, however, only in case where Lund Elmer Sandager finds it appropriate. Once the case has been processed, you will be informed of the outcome if possible in accordance with the law.
A lawyer from Lund Elmer Sandager makes the initial assessment and the case processing itself. When Lund Elmer Sandager has collected enough information, we involve one or more appointed contact persons to help find a solution.
If your report concerns one of the contact persons appointed by Novafos A/S, Lund Elmer Sandager will assign the case to another contact person. If the report concerns all contact persons at Novafos A/S, Lund Elmer Sandager will contact the relevant management of Novafos A/S who is not involved in the case to agree the further steps in the case.
The assigned contact person in Novafos A/S only receives information about the content of the report and, thus, not the entire dialogue between you as the reporter and Lund Elmer Sandager. Even if you have made a confidential report, and thus not an anonymous report, only Lund Elmer Sandager can see your personal information.
The person or persons affected by your report will, as a main rule, only be notified when the case has been thoroughly investigated. Regardless of whether your report is made confidentially or anonymously, your personal information will not be passed on to persons involved in the reported case. However, you should be aware that some situations allow people covered by your report to figure out your identity. This may be the case, for example, if you report incidents where only a few people were present.
It is important that you continuously log on to your case as long as it is being processed. It helps to ensure a thorough investigation so that Lund Elmer Sandager gets all the necessary information to ensure completion of the case. You can stay anonymous throughout the entire process if you prefer so.
As a rule, whistleblower cases are processed within 3 months. You can stay informed by logging in to your case on the Platform. Do not worry if you do not experience any developments in your case for periods as the case processing may take some time before you are informed.
Security and anonymity
Lund Elmer Sandager handles the case and protects your identity. However, you should be aware that depending on the situation you are reporting, there may be someone in Novafos A/S who can still figure out your identity. However, your identity will not be confirmed or denied by Lund Elmer Sandager.
If you report confidentially, Lund Elmer Sandager may see your personal information and contact details, but it will not be passed on to Novafos A/S.
If you report anonymously, your identity will not be known to anyone, and you will not be asked to provide contact information. Lund Elmer Sandager recommends that you do not inform anyone in the company about your case. You are also recommended to use an e-mail address other than your work e-mail if you report confidentially.
As a whistleblower, you have the option to choose whether you want to report confidentially or anonymously. During the process, you can choose to go from anonymous to confidential, but you can never become anonymous again if you have first chosen confidential.
"Anonymous": Your identity will never be revealed to any parties as you will not be asked to provide name, e-mail or phone number. Therefore, you will not receive notifications by e-mail if there is any news in your case on the Whistleblower Platform. (The dialogue with Lund Elmer Sandager is only through the Whistleblower Platform if you choose to be "anonymous".) As anonymous, your IP address is not logged, but if you use your company network, the company can see that you have accessed the website URL. However, it is not possible to see which site you have accessed on the platform or whether you have entered information or made a report.
"Confidential": If you want to disclose your identity to Lund Elmer Sandager, you can select "Confidential". You will be asked to provide your name, e-mail and telephone number. As such, you will receive a message by e-mail when there is news in your case. Novafos A/S still does not have access to your identity.
If you do not know which one to choose, you can always create your case anonymously, and later choose to disclose your identity to Lund Elmer Sandager by changing your status at the platform.
Yes. The content of your case is always encrypted. However, we recommend that you use a private email address if you report confidentially.
If you do not want your employer to see on the web traffic that you have visited the Whistleblower Platform, we recommend that you use another network.
Yes, all data is encrypted both during transmission and during storage.
No. We clean MS Office documents, images and other files for metadata such as your name, your initials, geotags and so on. However, your name and other personal information may appear in the content of the document itself which will then be disclosed to Lund Elmer Sandager.
For security reasons, it is not possible to access a case without the original code. The code cannot be resent. You should therefore start the process again and create a new report at the Whistleblower Platform.
Report securely and anonymously via the Whistleblower Platform. Follow the instructions that guide you through the reporting process. When you press submit, you will see a confirmation of receipt on the screen and be given a code that you will need to be able to access the case again later in the process. It is therefore important that you store this in a place that only you have access to.
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