Whistleblowing statement
Penneo is part of the Visma Group and therefore included in Visma’s Whistleblower Channel. As such, Penneo employees and stakeholders can report concerns or potential violations in accordance with Visma’s whistleblower policy and procedures.
Visma’s whistleblower policy and procedures
Visma will not tolerate any form of misconduct or critical conditions, such as violations of statutory rules, internal rules, policies or ethical standards, such as bullying, harassment, discrimination, corruption, money laundering or any other financial fraud, and will make efforts to ensure a safe, healthy and legal environment in all our business activities and companies.
Visma will comply with all applicable laws and regulations and act ethically and socially responsible. Breaches of any local and/or EU/EEA law may result in disciplinary actions, including termination / dismissal and reports to the relevant authorities.
The Visma Whistleblowing Channel is a tool enabling anonymous submission of any suspected breach of the local and/or EU/EEA law from both inside Visma and outside. It fosters confidential communication between reporter and Case handler and the reporter may rest assured that any Report is being handled in a discrete, professional and respectful manner – and by the correct, dedicated Case handler in each case.
Visma Whistleblowing is compliant with the EU Whistleblower Directive (Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law) and the regulations regarding whistleblowing in the WEA (local working environment and protection laws). Visma is also, in some jurisdictions, due to being licensed by local Financial Supervisory Authorities, obliged to have a specific whistleblowing system in place.
Who can report
This procedure applies to a Notifier who needs to report a breach or a potential breach of the local or EU/EEA law or any of Visma’s internal rules/policies, such as Visma’s Code of Conduct.
It also applies to third persons who are connected with the Notifier, and who could suffer retaliation in a work-related context, such as colleagues or relatives of the Notifier.
As a Notifier, you are protected by law. You should not be treated unfairly or lose your job because you ‘blow the whistle’. You may also rest assured that the Report will not be handled by persons involved in the case, in order to avoid retaliation and uncomfortable situations. Visma welcomes all reports on any breaches of the above mentioned regulations and Intake Management will make sure each case is directed to the correct Case handlers in each case.
Example: a Notifier wants to report on harassment from their HR resource in the company. If the HR resource in fact is the Case handler in the company, Intake Management will make sure the Report will not be directed to that Case handler and instead reach out to the back-up Case handler or – if the case is not suitable for the back-up Case handler – the Country Manager or the Whistlelink Administrator to discuss to whom the Report should be directed to.
What can be reported
All reports shall be based on justifiable grounds of suspicion. Evidence is not necessary, but reporting must not be made with the intention to cause harm or with the knowledge that the accusation is false. Hence, the Report you disclose must be made in the public interest. To identify if a Report is in the public interest, you should look at the following criteria:
- the number of people affected
- the nature or impact of the harm
- who is the reported individual
- the severity of the case.
In a nutshell, the Report should go beyond the employee’s personal circumstances.
Some examples, include the following:
- a criminal offence, for example, fraud, bribery, money laundering
- someone’s health or safety is in danger
- risk or actual damage to the environment
- a miscarriage of justice
- the company is breaking the law – for example, it does not have the right insurances
- you believe someone is covering up wrongdoing
- harassment and bullying between colleagues or from the leader
- unhealthy psychosocial working environment
- #MeToo cases
Whistleblowing that fulfils this criteria shall be treated as “Qualified Reporting” and handled in accordance with this procedure.
What should not be reported:
Types of cases other than those listed above should not be reported. Such cases that do not fulfil the criteria will be treated as “Non-qualified reporting”. A non-qualified reporting will not be handled within the Whistleblowing Procedure.
Examples of cases that should not be reported through the Whistleblowing Channel are:
- General opinions on how the business is run
- General opinions on salary, leadership or other personnel matters
Such cases shall be handled by reporting to the relevant manager or any other relevant person within the management of the company in question.
A standard response will be sent to the Notifier in case of a “non-qualified reporting”.
Your report
Your report should contain the following information:
- The type of misconduct you wish to report.
- Where it has taken place.
- When it happened. Provide time and date and if anything is recurring.
- Documentation in any form if you have access to it. If you don’t have access but know documentation exists, include what type of documentation it is and where it can be found.
- Details of any other action that you have taken in relation to the misconduct.
Note! It is important that you read and understand the privacy notice for employees before submitting your report (see link on the right side). Any personal data that is clearly not relevant to your report should not be submitted. We may delete it without informing you if you still submit such information.
How your report is handled
Based on current legislation, the organisation will make an initial assessment of your report to determine whether it is applicable for being handled in the whistleblowing channel.
All reports will be assigned a unique case number, and you will receive a verification code to confirm receipt of your report.
You will receive the confirmation within seven days of acknowledgement of your report. You can use the verification code to submit additional information or get feedback on the case. The company will get in touch with you on how the case has been handled within 90 days.
Anonymity
You remain completely anonymous when you submit a report unless you voluntarily provide personal information. There is no obligation to provide any personal information.
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.