Acoplastic’s Whistleblower Policy

The whistleblower policy aims to explain how the whistleblower system works at Acoplastic. The policy further aims to ensure that potential misconduct reports are not withheld due to lack of clarity on the whistleblower system.


Acoplastic’s Whistleblower system 

Acoplastic has established a whistleblower system following the EU Directive 2019/1937.

Acoplastic’s whistleblower system is operated by WhistleSystem ApS, ensuring a completely anonymous and secure process for the whistleblower. The whistleblower system shall be used if employees or other stakeholders experience serious misconduct or offences in relation to Acoplastic. Examples of what can be reported is further described in the whistleblower policy under “What can be reported?”. 

Acoplastic encourages you to contact your manager about incidents or misconduct. However, this is not always the most optimal approach and can cause reports to be withheld. Therefore, Acoplastic has established a whistleblower system that, if you do not want or can go to your manager, or simply wish to remain anonymous, makes it possible to still report the offence.

Reports can be made by anyone with access to the system. At Acoplastic, this includes internal stakeholders who have experienced misconduct.

The whistleblower’s report can include people, situations, and incidents. All stakeholders can be reported if the report is relevant under the criteria in “What can be reported?” in this policy and is related to Acoplastic.

Acoplastic has appointed the following administrator team:

Administrator (Carsten Grue Andreassen), Administrator (Morten Andreasen), Administrator (Lars Appel)

 

What can be reported?

The whistleblower system can only be used to report serious misconduct or violations. Subjects such as cooperation difficulties, dissatisfaction with facilities, or dissatisfaction with conditions cannot be reported through the whistleblower system. In such cases, please refer to your manager.

Examples of subjects that can be reported through the whistleblower system include, but is not limited to, the following points.

  • Sexism
  • Sexual assault
  • Physical violence
  • Discrimination
  • Economic crime
  • Workplace safety
  • Consumer protection
  • Product safety
  • Breach of procurement legislation
  • Breach of GDPR legislation
  • Breach of environmental legislation
  • Money laundering

However, it is Acoplastic’s policy that we would rather have one report too much than one too little, to ensure that we receive all relevant reports. This means that if you are unsure whether you report can be reported under the whistleblower legislation, you are encouraged to submit the report. 

 

How do you report?

Reports are sent through WhistleSystem.

Whistleblowers can access the system and report as follows:

1. Go directly to Acoplastic’s Whistleblower System

2. Fill the form with the necessary information and documentation, so the administrator team can process the report effectively.
The report is completely anonymous. WhistleSystem is the only channel at Acoplastic where misconduct can be reported anonymously.

Reports can be submitted by all relevant stakeholders with whom Acoplastic has shared the access information to the system. 

After the report is submitted, a unique report ID will appear, which must be saved and kept in a safe place. You can log in and reopen your report with your report ID. This allows you to start an anonymous dialog, send further documentation, and answer clarifying questions from the administrator team. Acoplastic encourages the whistleblower to log in regularly after the report has been submitted to respond to any follow-up questions.

Please see the user manual for a detailed description of the reporting process.

How are reports processed?

The reports are processed by Acoplastic’s administrator team. 

The process proceeds as follows:

  1. The administrator team will notify the whistleblower that the report has been received within 7 days. 
  2. The administrator team assesses and categorizes the report and conducts an initial investigation. At this stage, it is possible that the administrator team needs more information or documentation from the whistleblower. The team will start an anonymous dialogue with the whistleblower through the system. 
  3. The processing of the report is based on the type and severity of the report. Initially, the report is processed internally. In case of particularly severe misconduct or violations, the authorities can be involved in the investigation.
  4. The whistleblower is informed of the actions taken within 3 months of the submission of the report. In long-term cases, the whistleblower is updated on a regular basis.
  5. Any personal information in the report is processed to remain GDPR compliant. 
  6. The report is deleted from the system when it is no longer relevant.

 

Retaliation 

The directive states that whistleblowers cannot be punished for reporting misconduct or violations. Thus, the whistleblower should not be concerned about private or career consequences following the report. If the report is relevant under the Whistleblower Directive, the whistleblower will not be punishable by Acoplastic after submitting the report. 

This includes the following penalties (retaliation):

  • Termination
  • Suspension
  • Degradation
  • Failed promotion
  • Change in working time and tasks
  • Decline in wages
  • Intimidation, harassment, and social exclusion at work

Acoplastic’s whistleblower policy aims to encourage greater transparency and security for all employees and stakeholders.

 

Security

The system utilizes several security measures that protects the whistleblower and the system in general. Some of these include:

  1. Full encryption throughout the process
  2. ISO 27001 certified (Information security)
  3. ISO 27701 certified (GDPR compliance)
  4. ISO27001 approved servers in Europe
  5. Schrems II compliant
  6. SSL technology
  7. Shield and WAF on application level
  8. Two-factor authentication at administrator level’
  9. Redundancy at both application and database level
  10. Architecture built on the latest technology
  11. Continuous AI monitoring
  12. No IP logging

 

Questions

Questions about Acoplastic’s whistleblower system can be directed to: 

Administrator (Carsten Grue Andreassen), Administrator (Morten Andreasen), Administrator (Lars Appel)