Whistleblower Channel



Penneo Whistleblower Policy



The purpose of the Whistleblower channel is to provide possibility and protection for current and former employees (Internal Whistleblowers) and external customers, vendors, consultants and other persons related to Penneo (External Whistleblowers) together (Reporting Individuals) by creating an independent and autonomous channel to report relevant violations, issues or concerns, as defined in this Policy.

Penneo also strives for an open and clear communication with externals, wherein they should feel comfortable and certain that they can safely report concerns, to their point of contact in Penneo as External Whistleblowers.

Penneo however also recognizes that there may be a number of instances and contributing factors that would cause an individual not to report an incident, in accordance with Penneo’s internal guidelines.
There may also be instances where an individual has raised concern within Penneo, but does not find that this concern has been appropriately addressed.

These violations, issues or concerns can instead be reported to the Whistleblower channel, granted that these fall within the scope of this Whistleblower Policy.



By implementing this policy and Whistleblower channel, Penneo ensures that suspected legal or code of conduct violations may be reported quickly and confidentially.

Furthermore, the whistleblower program is required by Danish law, so that in-house whistleblowers are able to report potential violations of relevant legislation through a specific, independent and autonomous channel.

Since Penneo is committed to fostering a workplace contributing to open communication regarding our business practices, we want the Whistleblower channel to protect the Reporting Individuals from any retaliation and discrimination for properly disclosing illegal or unacceptable conduct, as defined below.


What should be reported through the Whistleblower channel?

Internal and External whistleblowers should report legislative violations, misconduct or suspicions hereof, that may influence Penneo or the wellbeing of persons related to Penneo as a company.

The following list is non-exhaustive, and Penneo advises all Individuals to report any good-faith suspicions they may have, of any violation or misconduct in the areas such as the following:

a) Economic crimes, including:

  • Making or offering bribes, payoffs or kickbacks
  • Committing or attempting to commit fraud or insider trading;
  • Committing or attempting to falsify documents or forgery;
  • Involvement in money laundering or terrorism financing;

b) Actions directed towards/committed by Penneo employees, including, but not limited to;

  • Assault or physical violence
  • Sexual harassment
  • General misconduct (intoxication at work, inappropriate behavior, discrimination)

c) Criminal offences or unlawful behaviour in relation to, but not limited to; National criminal legislation, the EU General Data Protection Regulation, Competition law.


What information should be submitted when reporting?

When submitting a report, there is some information that will be useful in assessing the seriousness of the issue or concern:

  • Who wants to make the report (name, place of work and contact details)
  • Description of the alleged violation, including names of any persons involved in the violation, as well as the date and place of the violation;

By letting us know who you are, we can contact you directly to discuss your concerns which will help us investigate the complaint more quickly and efficiently. You will always when reporting, be assigned a member of the Legal team to assist with any questions or concerns that you have about the process.

Other elements to submit:

  • If the possible violation is expected to reoccur;
  • If any other person within Penneo knows of the violation or is expected to have this knowledge as well;
  • Any document or evidence relating to the possible violation
  • Any other detail or information that may facilitate the investigation will be appreciated



Issues reported to the Whistleblower channel will be handled internally by the Penneo Legal Department.

The Reporting Individual can choose whether their report should be anonymous or not. Penneo always recommends that the reporter is not anonymous. Knowing the identity of the Reporting Individual ensures that Penneo can reach out for further information and thereby better address the concerns which have been reported.

However, if the report is made anonymous, the Reporting Individual can still choose to anonymously communicate through the Whistleblower channel platform with the Penneo Legal Department, to further expand upon their report or edit previously submitted reports.

Depending on the level of severity of the issues or concerns raised in the report, Penneo’s Legal Department can choose to further report the issue to be independently handled by a third party, which will be an external law firm.


What should not be reported:

It is important to note that there are issues and concerns which are not relevant or eligible for reporting under this policy and therefore should not be reported through the Whistleblower channel.

This could be, but is not limited to:

  • Complaints about day-to-day personnel issues or routine employee matters
  • Interpersonal conflicts and cooperation problems


What happens after you make a report?

The Legal Department receives the report and will respond with an acknowledgement of receipt within 7 days. The Legal Department will then evaluate the report’s category, the severity of the claims raised and whether or not the report must be communicated to the relevant governmental authorities.

Depending on the contents of the report the Legal Department may reach out to the reporting individual, however always through the Whistleblower channel platform. All contact is confidential.

Should the report or concern prove valid or be reasonably suspected to prove valid, it may be required by Penneo to notify third parties of the allegations and the investigation, such as contract parties as well as public authorities, however, only subject to applicable law.

Furthermore, if a report submitted regards relevant financial legislation, the report is considered confidential information within the scope of the law. Such confidential information, including the name and/or identity of the reporting individual, may not be disclosed without proper authorization.

Penneo will not tolerate retaliation or punishment of any kind against any Relevant Individual making a good-faith complaint or assisting Penneo in the investigation of any report. This includes any reprimand, reprisal, change in work duties, change in employment amenities, damage to career prospects or reputation, or deliberate omissions that may harm the individual.


False claims in reports:

Reporting Individuals who knowingly and maliciously make a false claim against somebody will not be protected by the whistleblowing legislation or by Penneo. Those who report in bad faith may be subject to civil, criminal and administrative penalties as well as disciplinary action, including termination of employment.


Privacy statement

Persons registered in connection with the Whistleblower Policy, including the accused person and the whistleblower, have the right to request access to data registered about them to check its accuracy and rectify it if inaccurate, incomplete or outdated.

The personal data processed in connection with the Whistleblower Policy will be stored for as long as needed, for the purpose for which it was collected. This may be dependent on whether the report is investigated, and if there are legal proceedings following the investigation.

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