At Hubbau we strive to maintain an open and transparent workplace, where misconduct should not occur. It is therefore important to us that there is clear information on how to report confidentially and safely. In the event of suspected ongoing or past misconduct, resources should be available to expose them. By making it easy to report, we collectively work to promote the trust of employees, customers and the general public in us.
Our cases are initially handled by the law firm Starck and Partner to guarantee independent handling of cases. Our internal contact persons may subsequently take over the case from the initial case handlers. See more information and contact details under "6.1 Contact details for case handlers".
You can whistleblow and receive protection under the Whistleblowing Act if you are an employee, volunteer, intern, active shareholder, person otherwise available for work under our control and direction, or a member of our administrative, management or supervisory body. Contractors, subcontractors and suppliers to us who have become aware of misconduct within the company may also report.
The fact that you have ended your work-related relationship with us, or that it has not yet begun, is not an obstacle to reporting misconduct.
If you suspect a possible misconduct, legal or regulatory violation, we encourage you to report this to us as a whistleblowing case. When reporting, it is important that at the time of reporting you had reasonable grounds to believe that the information about misconduct being reported was true. When assessing whether reasonable grounds existed, the circumstances and information available to you at the time of reporting shall form the basis for whether you could have assumed the misconduct to be true. The above requirements must be met in order for you to receive protection under the Whistleblowing Act.
Before you blow the whistle, read 5 questions to determine whether you are protected by the Whistleblowing Act.
You may report information about misconduct that has come to light in a work-related context and where there is a public interest in it being disclosed. For other types of personal complaints that do not have a public interest in being disclosed, such as disputes or complaints regarding the workplace or work environment, we encourage you to instead contact your immediate manager, HR, or another appropriate responsible person. This is to ensure that these matters are handled in the best possible way.
Examples of serious misconduct that may be reported include:
There is also the possibility of reporting information about misconduct that has come to light in a work-related context and that violates EU legal acts or provisions. If you suspect that this is occurring, please refer to Section 2 of the Whistleblowing Act and the scope of the Whistleblowing Directive in Article 2 and Annex Part 1 for applicable laws.
For a written case, we use our digital whistleblowing function Visslan. It is always accessible at https://hubbau.se/visselblasning. On the website, select "report" to describe your suspected misconduct. Please describe what has happened in as much detail as possible, so that we can ensure that adequate measures can be applied. It is therefore also possible to attach additional evidence, such as written documents, images or audio files.
Please do not include sensitive personal data about persons mentioned in your report unless it is necessary to describe your case. Sensitive personal data includes information about ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, a person's sex life or sexual orientation, genetic data, and biometric data used to uniquely identify a person.
You may remain anonymous throughout the entire process without it affecting your legal protection, but you also have the option of disclosing your identity under strict confidentiality. Anonymity may in some cases make it more difficult to follow up on the case and limit the measures we can take, but in such cases we may also later ask you to disclose your identity under strict confidentiality at a later stage.
After submitting your report, you will receive a sixteen-digit code, which you will be able to use to log in to Visslan at https://hubbau.visslan-report.se/. It is very important that you save this code, as you will otherwise not be able to access the case again.
If you lose the code, you may submit a new report referencing the previous one.
Within seven days, you will receive a confirmation that a case handler has received your report. The case handler is the independent and autonomous party who receives cases in the reporting channel, whose contact details are attached in "6.1 Contact details for case handlers." For questions or concerns, you and the case handler can communicate going forward through the platform's built-in and anonymous chat function. You will receive feedback within three months regarding any measures planned or taken as a result of the report.
It is important that you log in regularly using your sixteen-digit code to respond to any follow-up questions the case handler may have. In some cases, the matter cannot be taken further without answers to such follow-up questions from you as the reporting person.
It is also possible to conduct an oral case by uploading an audio file as an attachment when creating a case at https://hubbau.visslan-report.se/. You then select "Yes" on the question about evidence in order to upload your file. In the audio file, describe the same facts and details as you would in a written case.
Additionally, a physical meeting with the case handler may be requested via Visslan. This is most easily done by either requesting it in an existing case or by creating a new report.
We encourage you to always first report misconduct internally, but if difficulties arise or it is considered inappropriate, it is possible to conduct an external report instead. We refer you to contact the competent authorities or, where applicable, EU institutions, bodies or agencies. Contact details for these can be found at the following web address: External reporting channels for whistleblowing.
During the handling of the case, it will be ensured that your identity as the reporting person is treated confidentially and that access to the case is prevented for unauthorized personnel. We will not disclose your identity without your consent unless required to do so by applicable legislation, and we will ensure that you are not subjected to retaliation.
When blowing the whistle, there is protection against negative consequences arising from having reported misconduct, in the form of a prohibition on retaliation. The protection against retaliation also applies, in relevant cases, to persons in the workplace who assist the reporting person, your colleagues and relatives in the workplace, and legal entities that you own, work for, or are otherwise connected to.
This means that threats of retaliation and attempts at retaliation are not permitted. Examples of such actions include being dismissed, having your duties changed, being subject to disciplinary measures, being threatened, discriminated against, blacklisted within your industry, or similar actions as a result of having blown the whistle.
Even if you are identified and subjected to retaliation, you are still covered by the protection, provided that you had reasonable grounds to believe that the misconduct reported was true and within the scope of the Whistleblowing Act. Note, however, that protection is not granted if it is itself a criminal offence to obtain or have access to the information that has been reported.
Protection against retaliation also applies in legal proceedings, including with regard to defamation, copyright infringement, breach of confidentiality obligations, violations of data protection rules, disclosure of trade secrets, or claims based on private law, public law or collective labour law, and you shall not be held liable in any way as a result of reports or disclosures, provided that you had reasonable grounds to believe that it was necessary to report or disclose such information in order to expose misconduct.
The protection also applies in the event of public disclosure of information. It is then required that you have reported internally within the company and externally to an authority, or directly externally, and that no appropriate action has been taken within three months (in justified cases, six months). Protection is also granted when you had reasonable grounds to believe that there may be an obvious risk to the public interest if the information is not disclosed, for example in an emergency situation. The same applies when, in the case of external reporting, there is a risk of retaliation or it is unlikely that the misconduct will be remedied effectively, for example where there is a risk that evidence may be concealed or destroyed.
Please note, however, that this protection does not apply if you as the reporting person disclose information directly to the media in accordance with an otherwise applicable system of protection for freedom of expression and freedom of information. You therefore still have source protection and the right to provide information to the media where applicable.
If you have requested a meeting with a case handler, they will, with your consent, ensure that complete and accurate documentation of the meeting is retained in a durable and accessible form. This may be done, for example, by recording the conversation or by taking minutes. Afterwards, you will have the opportunity to review, correct and approve the minutes by signing them.
If the conversation was not recorded, the case handler has the right to document the conversation through minutes. Afterwards, you will have the opportunity to review, correct and approve the transcript by signing it.
We recommend that this documentation be kept in the Visslan platform by having the whistleblower create a case where the information can be gathered securely.
If you have further questions about how we handle whistleblowing cases, you are always welcome to contact the case handlers.
For technical questions about the Visslan platform, please create a case at https://hubbau.visslan-report.se/. If that is not possible, contact The Whistle Compliance Solutions AB, who developed Visslan. Contact details are provided below.
Name: Marita Bark (external)
Company/Position: Starck and Partner
Email: marita.bark@starckpartner.se
Phone number: 08-40 90 46 48
Name: Jesper Wigzell (external)
Company/Position: Starck and Partner
Email: jesper.wigzell@starckpartner.se
Phone number: 08-4090 46 52
Name: Jesper Kemme (internal)
Company/Position: Hubbau, Business Developer
Email: jesper.kemme@hubbau.se
Phone number: 0706 717 802
Email: clientsupport@visslan.com
Switch: +46 10-750 08 10
Direct number (Daniel Vaknine, CEO): +46 73 540 10 19
Visit Visslan's website for more information about Visslan.
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