Matkahuolto’s whistleblowing hotline and instructions for reporting

WE WANT TO DO IT CORRECTLY

To ensure that our operations are in compliance with the applicable law and our Ethical Code of Business Conduct, we provide a whistleblowing hotline accessible to all for reporting cases of misconduct. It is intended for reporting material infractions in the company or its activities that could result in administrative sanctions (such as a fine) or criminal liability for the company or the person committing the infraction. It is of primary importance for us that we have the opportunity to address problems and improve our performance.

It is important that each employee reports any suspected misconduct that is not in compliance with Matkahuolto's Ethical Code of Business Conduct. This offers us the opportunity to act on any shortcomings in our operations. While you are not required to present any evidence in support of your suspicions, you need to be honest when reporting and act in good faith convinced that your concerns are legitimate. The whistleblower will not be subjected to any negative consequences.

We encourage you to identify yourself when reporting your concerns using the whistleblowing hotline. If you wish, you may also file your report anonymously. However, to investigate cases involving discrimination, harassment, bullying or unequal treatment, it is practically necessary to discuss the subject of the report and look into the matter more closely. Hence, if your report relates to any of the foregoing themes, you should, as a rule, disclose your name.

To ensure anonymity, the whistleblowing hotline is managed by an external partner, WhistleB, Whistleblowing Centre. The reporting procedure is encrypted and password-protected. All reports are processed in confidence in accordance with Matkahuolto’s standard protocol.

Please note that ordinary customer feedback can be filed using the appropriate channels:
www.matkahuolto.fi/feedback.

Matkahuolto’s whistleblowing guidelines

Matkahuolto’s whistleblowing guidelines

Use the whistleblowing hotline to report any suspicions of misconduct related to Matkahuolto’s operations.

Other feedback

Please note that the whistleblowing hotline is not intended for giving ordinary customer feedback. For that, use the feedback form.

Instructions for reporting

1. Introduction

It is of utmost importance for Matkahuolto that everyone reports any detected or suspected misconduct or activities that are at variance with the law or our Ethical Code of Business Conduct. You are requested to report events and incidents that do not comply with our responsible and ethical way of working. This will help us address potential violations of the law or ethical business practices and prevent similar misconduct in the future.
We are committed to ethically sustainable practices and a culture of transparency, and to maintaining an organisational culture in which everyone can report concerns about misconduct in violation of the Code of Conduct without the risk of subsequent victimisation, discrimination or disadvantage. No one who honestly and in good faith reports their suspicions and participates in the investigation of potential violations of the Code of Conduct will incur any negative consequences.

The purpose of these whistleblowing guidelines is to encourage people to report activities that are contrary to the Code of Conduct.The whistleblowing hotline is an important tool for reducing risks and maintaining trust.

We encourage you to identify yourself when reporting your concerns using the whistleblowing hotline. This makes it easier to investigate the issue in response to your report. If you wish, you may also file your report anonymously. However, to investigate cases involving discrimination, harassment, bullying or unequal treatment, it is practically necessary to discuss the subject of the report and look into the matter more closely. For this reason, you need to disclose your name when reporting concerns related to these problems.

2. When should a report be filed?

The whistleblowing system can alert us to serious risks that individuals, businesses, society or the environment may be exposed to.

It provides a framework for processing information concerning instances of material misconduct that could result in administrative sanctions (such as a fine) or criminal liability for the company or the person guilty of misconduct in relation to the following:

violations of competition law
misconduct related to public contracts
bribery and corruption, including failure to recuse oneself in case of conflict of interest
violations related to privacy and the protection of personal data
failure to fulfil obligations related to the prevention of money laundering and terrorist financing
road safety in parcel transports
infringements of consumer protection regulations
environmental protection
infractions of occupational health & safety regulations
discrimination, harassment, bullying or unequal treatment
misconduct within the company, such as theft of assets or misrepresentation of financial information for misleading purposes
other material breaches of the company's Code of Conduct that may affect the company's business, financial performance, reputation or stakeholder confidence.

Whistleblowers are not required to present solid evidence in support of the misconduct before reporting their suspicions. However, the reports must be honest and filed in good faith. They may not contain any deliberately false or misleading information. When filing the report, the whistleblower must have well-founded reasons for believing that the information concerning the alleged misconduct is true. Any misuse of the whistleblowing hotline is a serious infraction that will have consequences.

Please note that ordinary customer feedback can be filed using the form specifically intended for this purpose. The feedback form is available here: https://www.matkahuolto.fi/feedback.

3. How should a report be filed?

Use Matkahuolto´s whistleblowing channel at: https://report.whistleb.com/en/matkahuolto-ext

We encourage anyone reporting suspicions to disclose their identity openly. All the reports received will be processed in confidence. However, if you wish to remain anonymous, you may file your report anonymously. The whistleblowing hotline permitting anonymous reporting is administered by an external service provider, WhistleB. All messages are encrypted. WhistleB protects the anonymity of the whistleblower by deleting all metadata, such as IP addresses. The identity of the person sending the report will remain undisclosed even in any further discussions with the processors.

4. Investigation process

All reports are processed in confidence by designated individuals in accordance with Matkahuolto’s standard protocol. Ultimate responsibility for processing rests with the General Counsel and the person responsible for internal audits. If necessary, other experts may also be called in to ensure that the report is handled properly.

The reports filed using the whistleblowing hotline can only be accessed by designated processors. Each processor is bound by a non-disclosure obligation to guarantee the confidentiality of the processing. The whistleblower’s name is not disclosed to the person that the report relates to except with the whistleblower’s consent. In the course of processing the report, the processor may approach other persons for information or expert assistance. All this will take place in full confidence.

The whistleblower’s identity may be disclosed if such disclosure is necessary for the purpose of a criminal report, pre-trial investigation or court proceedings, or if the company is otherwise required to do so by law or an order issued by a public authority.

Receiving reports

All reports are taken seriously. Upon receipt of the report, the processors make a decision on whether to launch an investigation.

The processors may disregard a report if it is manifest that:

the issue raised in the report is not included in the range of matters for which the whistleblowing hotline is intended;
the report has not been filed in good faith or it is motivated by a desire to inflict harm;
the information available is insufficient for launching an investigation and the whistleblower fails to provide additional information despite follow-up questions or a processor’s request to do so; or
the issue raised in the report has already been cleared up.

Investigation in response to a report

All reports of suspected misconduct or irregularity falling within the scope of the whistleblowing hotline will be investigated in accordance with these guidelines. The adequate method of investigation will be determined by the processors.

All reports will be treated in confidence.
No person whom report concerns or who is somehow associated with the subject will take part in the investigation.
If necessary, the processors will ask follow-up questions using the anonymous whistleblowing hotline.
None of the processor or anyone else involved in the investigation process will make any effort to identify the whistleblower, unless he or she wishes to leave his or her contact details.

The whistleblower will receive an acknowledgement of receipt within seven (7) days of receipt of the report. The whistleblower will receive feedback in response to his or her report no later than three (3) months of the dispatch of the acknowledgement of receipt.

Reports submitted by identified whistleblower

The whistleblower’s name will not be disclosed to persons other than the processors.

Processing of personal data

The whistleblowing hotline processes the personal data provided by the whistleblower, including data of the person identified in the whistleblowing report, the person sending the report (if the report is not sent anonymously) and any third parties involved, in order to investigate the suspected misconduct in violation of the law or our Code of Ethics. Such processing is based on law and a legitimate interest.

To read the Privacy Statement of this service, click here.

Deletion of personal data

All personal data contained in the reports will be deleted when no longer needed for investigation and enforcement purposes, usually within one month (30 days) of the completion of the investigation. The investigation records are anonymised and names and addresses deleted, including all other information by which a person could be identified directly or indirectly on the basis of such other information.

File controller of the personal data

Oy Matkahuolto Ab, <Riku Korpela, General Counsel, riku.korpela@matkahuolto.fi>, who is responsible for the personal data processed in the whistleblowing hotline.

Processor of personal data

WhistleB Whistleblowing Centre Ab (World Trade Centre, Klarabergsviadukten 70, SE-107 24 Stockholm) is responsible for the whistleblowing software, including the processing of confidential information such as whistleblowing reports. Neither WhistleB nor its subcontractors are able to decrypt messages and read reports. Hence, WhistleB or its subcontractors do not have access to any readable content.

5. Legal basis for the whistleblowing guidelines

This practice is based on the EU General Data Protection Regulation and the EU Whistleblower Protection Directive. These guidelines will be updated as necessary when national legislation on whistleblower protection enters into force.

6. Transfer of personal data to outside the European Economic Area

No data will be transferred outside the EU or EEA.