Whistleblower scheme

Politiken last updated: 2024-26-09
Approved by: Board of Directors

 

Purpose
Triarca A/S is committed to the highest possible standards of openness, honesty and accountability. The purpose of this policy is to provide Triarca's internal and external stakeholders with a framework for reporting suspected misconduct within the company without fear of retaliation.

It is also intended to encourage all employees and other stakeholders to report suspected or actual violations of company policies, internal procedures or laws so that irregularities can be remedied before major damage occurs.

Triarca aims to achieve and maintain a corporate culture where reporting wrongdoing is encouraged and valued.


The policy was adopted by Triarca's Board of Directors on 23 March 2022.

The policy complies with 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 EU law.


Report a wrongdoing - Who can submit a report
A whistleblower is a person who reports errors in company operations. A report can be made by employees, suppliers, contractors, subcontractors, self-employed persons, volunteers and trainees, shareholders and members of the administrative, management or supervisory body of a company who are active in the company. This policy also applies to individuals previously employed by Triarca if the misconduct occurred during employment and individuals who have not yet joined Triarca where information about misconduct was obtained during the recruitment process or other pre-contractual negotiations.

   
What can be reported
The whistleblower system is for reporting actual or suspected misconduct within the Triarca Group and violations of laws and regulations. The information reported must be of interest to a wider group of people, not just the whistleblower, and there must also be a legitimate interest in the information being disclosed. A whistleblower does not need to have solid evidence to express a suspicion, but the report must have been made in good faith (i.e. have reasonable grounds to believe that the information about reported breaches was true at the time of reporting).

 

Examples of misconduct and violations of laws and regulations:


  • - Deviations from Triarca's Code of Conduct or other internal policies and procedures
    - Suspicion of corruption or conflicts of interest
    - Inadequate product safety
    - Inadequate handling of personal data
    - Environmental offences
    - Other violations of EU or national legislation

Triarca's whistleblower system is a confidential reporting channel through which a whistleblower is allowed to anonymously raise concerns about wrongdoing. The system is provided and managed by the independent external party DLA Piper Denmark. Reporting can be done 24 hours a day, all year round. In addition to the web-based solution, reports can also be submitted via a physical meeting or verbally via a telephone line.


The anonymous reporting function is accessed via: 

https://whistleblowersoftware.com/secure/952a6836-a224-4bd7-8a16-6f2753bb4a17


Phone line: +45 33 34 08 63 or +45 33 34 00 65 open from 09:00 - 15:00

 

When reporting misconduct, the whistleblower is strongly encouraged to provide as much detail as possible as this will enable a thorough and accurate investigation.

What happens after a report has been submitted. All concerns and complaints received through the whistleblower system will be immediately investigated by DLA Piper's experienced specialists. DLA Piper will provide an initial assessment and recommendation of incoming cases and send the report to the Whistleblower Committee in Triarca.


If the reported behaviour qualifies as a whistleblower case, the Whistleblower Committee will send the case together with clear recommendations for action to the Chairman of the Board. Depending on the nature of the case, the matter will be further investigated internally, referred to the police or other law enforcement authorities or be subject to independent and external investigation. DLA Piper and the Whistleblower Committee ensure that a report is not forwarded to anyone within Triarca who may be subject to the report.

 

 
Confirmation that the case has been received - Feedback on actions taken
The whistleblower will receive feedback on actions as soon as possible and within 3 months at the latest.


Reporting to authority

Reporting Persons should primarily use Triarca's reporting channel. Reporting persons may also report misconduct to an external reporting channel provided by an authority if it is not deemed appropriate to use Triarca's reporting channel.

It is also possible to report matters to the Danish Data Protection Agency. The Danish Data Protection Agency is a public authority that operates an external whistleblower scheme. It is optional whether you want to report a matter to DLA Piper or to the Danish Data Protection Agency.


However, we encourage you to use the internal reporting channel(s) above if the matter can be resolved quickly and efficiently by the company itself and you assess that there is no risk of you encountering obstacles or experiencing consequences by making an internal report.
You can read more about the Danish Data Protection Agency's whistleblower scheme and how to use it via the following link https://www.datatilsynet.dk/om-datatilsynet/kommende-whistleblowerordning.


Protection against retaliation
Triarca applies a zero tolerance for retaliation against anyone who reports wrongdoing in good faith. Whistleblowers will not be held liable for breaches of confidentiality, provided that at the time of reporting, the person had reasonable grounds to believe that reporting the information was necessary to disclose the reported misconduct, in accordance with applicable law. Individuals who knowingly report incorrect or misleading information are not protected from retaliation.


Anonymous and confidential reporting

The whistleblower system is provided by an external partner to ensure anonymity and confidentiality. Whistleblowers can choose to remain anonymous and the solution will ensure their anonymity all the way from reporting to dialogue, possible follow-up and investigation. All information revealed during the investigation will remain confidential, except when necessary to conduct the investigation and take any remedial action in accordance with applicable laws.


Personal data will only be processed if necessary to follow up on the reported case. Only persons designated to receive, follow up and provide feedback on reports can have access to the personal data. The personal data in the reports will be deleted when the data is no longer necessary or no later than two years after the case has been closed.