For Investors

Whistleblowing procedure at Fodelia Oyj and its subsidiaries

Fodelia Oyj and its subsidiaries operate in accordance with the law, the company’s values and the principles of ethically sustainable business practices. It is important to Fodelia to promote transparency and a culture of openness. The company aims to highlight issues and address them effectively. It is therefore important that everyone reports any suspected misconduct that does not comply with the law or the principles of good business practice. This enables the company to prevent, avert or rectify misconduct, and to develop its risk management and ethical organisational culture.

How should the notification be made?

The whistleblowing channel is a reporting channel through which all members of the organisation and external stakeholders can report their suspicions of misconduct if they suspect activities that are not in accordance with the law, the company’s operating principles, values or the principles of good business practice.

First and foremost, the company encourages staff to contact their line manager. If a person reporting an issue feels that they cannot share their concerns openly, they also have the option of raising their concerns anonymously.

There are various ways to submit a notification:

• Option 1: Report the matter to your own line manager or another line manager
  within your organisation
• Option 2. Report the matter to the company’s whistleblowing officer:
  Carola Rahkola, Head of HR at Fodelia Oyj, carola.rahkola@fodelia.fi
  
• Option 3. Anonymous report by
  post: Confidential/Carola Rahkola, Teknobulevardi 3–5, 01530 Vantaa

All reports must be made honestly and in good faith. Misuse of the whistleblowing service – that is, the deliberate reporting of false or malicious information – is a serious offence which may lead to further action. However, the reporter does not need to have solid evidence of misconduct before reporting a suspicion. Provided the reporter acts in good faith, it does not matter if their suspicion turns out to be mistaken.

The research process

All whistleblowing cases are treated in confidence. Everyone who receives such information is bound by a confidentiality agreement.

A person who is the subject of the allegation or who has links to it shall not take part in the investigation of the report. If a whistleblowing report concerns the Chief Financial Officer or another member of the whistleblowing team, they must recuse themselves from the investigation without delay. The Board will then appoint another person to investigate the whistleblowing report in question and to report on the findings of the investigation.

All reports are taken seriously. Upon receiving a report, the whistleblowing officer assesses what action the report requires. A report will be processed if it falls within the scope of matters to be reported under the whistleblowing procedure, has been made in good faith, and sufficient information is available to allow for further investigation.

A thorough investigation is carried out into all reports received. The whistleblowing officer draws up a written agenda covering all reports, which is submitted to the Board for consideration.

If it is appropriate to engage external advisers or experts in the course of the investigation or the analysis of the investigation’s findings, the company may also delegate responsibility for the investigation to experts outside the company.

Protection of whistleblowers

Everyone – including company employees, job applicants and business partners – must be able to report their observations in confidence. The company ensures that no one who reports actions that contravene the law or good business practice suffers any adverse consequences, such as discrimination or reprisals.

The person who made the report will be informed of the findings of the investigation. However, due regard will be paid to the privacy of those against whom the allegations have been made, as well as to other matters relating to confidentiality. If the matter involves a criminal offence, the reporter’s identity may have to be disclosed in the course of legal proceedings. The parties concerned have the right to access information relating to themselves and to request corrections if the information is incorrect, incomplete or out of date.

All personal data contained in whistleblowing reports will be deleted once it is no longer required for the purposes of investigation and enforcement. The data will be deleted no later than five years after the report is made, unless retention of the data is necessary for the purposes of handling the matter, protecting the parties involved or for any other similar reason.