Our system for reporting misconduct
The reliability, constant development and success of Eezy’s activities are based on ethically sound operations, the basic principles of which are recorded in our principles of sustainable business and good governance.
It is important that each person reports any suspected misconduct that is not in line with Eezy’s sustainable and transparent mode of operation. This enables us to prevent or correct any misconduct and minimise the resulting losses. The whistleblowing service gives Eezy the opportunity to develop our operations so that the detected misconduct cannot be repeated. You do not need to have conclusive proof to support your suspicions. A justified suspicion of possible misconduct is enough, but the reports must be made honestly and in good faith.
You can report your suspicion anonymously in the Eezy reporting channel for misconduct. The channel is managed by an external partner, WhistleB.
The anonymous whistleblowing channel can be found at https://report.whistleb.com/eezyext
You can access the whistleblowing channel on a computer, tablet computer or a smartphone, for example. We recommend sending the report from a device that is not connected to our intranet.
Find answers to any questions you may have:
✓ Instructions for reporting misconduct are available on this page.
✓ Frequently asked questions: (https://whistleb.com/faq/whistleblower)
✓ How to send my message? -Watch a short video
“WhistleB offers a third-party whistleblowing service that ensures the whistleblower’s anonymity as they communicate with their employer. The service is completely separate from the employer’s IT systems and online services. WhistleB does not store IP addresses or other identifying information. All the reports are encrypted and can only be decrypted by authorised individuals. WhistleB is unable to decrypt and read the reports.” WhistleB
Reporting and investigating misconduct at Eezy
(Whistleblowing channel)
1. Introduction – what does whistleblowing mean and why is it important?
Responsibility is at the core of making working life dreams come true. Our leadership and corporate culture are based on responsibility, which supports us in encounters with our employees and clients. On these values we will build a future Eezy that puts its employees first.
In addition to employment issues, we want to be a responsible actor in developing working life in the right direction. We feel that responsibility is important when producing services for our customers and partners.
Our whistleblowing service offers you the chance to confidentially report suspected misconduct at Eezy or one of its organisations or by individuals employed by Eezy. It is an important tool for reducing risks and maintaining trust as it helps us detect potential misconduct and take action at an early stage.
Anyone can submit a whistleblowing report either openly or anonymously.
2. When to report misconduct?
Eezy’s whistleblowing service can help us identify and prevent severe risks targeting individual people, the company, society or the environment. The service enables the processing of information on severe misconduct related to the following topics:
✓ accounting, internal bookkeeping audits, audits of the accounts, prevention of bribery, banking of economic offences;
✓ privacy and personal data prosessing problems, deficienciens in network and information systems
✓ Problems related to the implementation of consumer protection or restriction of competition; or
✓ other severe offences related to the vital interests of the company or the Group or the lives and health of individuals, such as severe environmental crimes, major shortcomings in workplace safety and extremely severe discrimination or harassment.
If the issue concerns dissatisfaction at the workplace or misconduct related to a different topic, primarily contact your supervisor as these issues cannot be investigated in a whistleblowing process.
The whistleblower does not need to have conclusive proof of misconduct before submitting a report on your suspicions. However, the reports should be submitted honestly and in good faith. A whistleblowing report that is unfounded or based on malicious intent is always a serious offence.
3. How to report suspected misconduct to Eezy?
You can express your concern in various ways:
✓ Option 1 Report the issue within our organization to your supervisor or another supervisor.
✓ Option 2 Contact: Ilpo Toivonen, Chief Legal Officer (ilpo.toivonen@eezy.fi / +358 (0)40 307 5003) or Mikko Innanen (Hanna Lehto), Director, People and Culture (mikko.innanen@eezy.fi / +358 (0)40 587 2923).
✓ Option 3 Report to the whistleblowing team anonymously in the whistleblowing service at: https://report.whistleb.com/eezyext
We encourage all those reporting their suspicions to openly disclose their identity. All the received reports are processed confidentially. However, if you do not wish to disclose your identity, you can submit an anonymous report. The whistleblowing channel enabling anonymous reporting is managed by WhistleB (external service provider). All the messages sent through the channel are encrypted. WhistleB secures the anonymity of the whistleblower by erasing all metadata, such as IP addresses. The whistleblower also remains anonymous in the follow-up discussion with those processing the report.
4. Investigation process for suspected misconduct
Whistleblowing team
Eezy has appointed a whistleblowing team for investigating suspected misconduct on the basis of whistleblowing reports. Reports submitted through the WhistleB channel can only be processed by the appointed members of Eezy’s whistleblowing team. Their activities in investigating the suspicion are recorded in a system log so that the integrity of the activities can be analysed later, if necessary. The activities related to investigating a reported suspicion of misconduct are absolutely confidential.
During the investigation, the whistleblowing team can request information and expertise from other individuals in order to examine the suspected misconduct. The individuals will only have access to information that is essential for the issue at hand.
They are bound by the same confidentiality requirements as the members of the whistleblowing team.
When a person reports a concern directly to a supervisor or the whistleblowing team in their own name, these instructions are followed in the investigation.
Receiving a report
After receiving a report, the whistleblowing team decides whether to accept or reject it. If the topic of the report is included in the scope of the whistleblowing directive, an investigation is launched. Learn more in section “Investigation” below.
The whistleblowing team may reject the report if:
✓ the alleged misconduct is not included in the whistleblowing topics listed in these guidelines;
✓ the report was not submitted in good faith or was made with malicious intent;
✓ the lack of information prevents further investigation;
✓ the reported issue has already been settled.
If the report covers topics not covered by the whistleblowing directive but their investigation is otherwise considered important in terms of the nature and scope of the issue, the whistleblowing team transfers the case to the correct party.
The whistleblowing team delivers the results of the investigation to the whistleblower within three (or a maximum of six) months of the date of receiving the report. The response should include a description of the action taken after receiving the report or the grounds for terminating the processing of the case.
Sensitive information concerning other individuals must not be attached to the report unless necessary for describing the concern.
Investigating suspected misconduct
Eezy takes all reports of misconduct seriously. The investigation complies with the following principles:
✓ The members of the whistleblowing team or other individuals participating in the investigation will not attempt to identify the whistleblower in any way.
✓ If necessary, the whistleblowing team may pose additional questions to the whistleblower or ask for additional information that is relevant for the investigation anonymously through the whistleblowing channel.
✓ Individuals directly concerned by the suspicion or individuals with other connections to the case must not participate in the investigation. These individuals are automatically disqualified from the case.
✓ The whistleblowing team decides whether to investigate the report and how to investigate it.
✓ All whistleblowing reports are processed with absolute confidentiality.
Protecting the whistleblower
Primarily, the whistleblower is always protected by complete anonymity unless they made the report in their own name or can otherwise be identified by the context. Eezy protects both anonymous whistleblowers and those sending a whistleblowing report in their own name against any direct or indirect counteraction and retaliatory action.
The whistleblower protection applies to individuals who have submitted a whistleblowing report in good faith concerning potential misconduct by Eezy or a person employed by Eezy. As a result, a whistleblower who presents a justified suspicion of misconduct is not in danger of losing their job or suffering any other direct or indirect consequences resulting from their report. The existence of misconduct is not a prerequisite for protection. The whistleblower is protected as long as the report was submitted with genuine concern over the existence of potential misconduct.
The results of the investigation are delivered to individuals who have submitted a report in their own name or otherwise in an identifiable manner in the same way as to individuals who have submitted a report anonymously. However, the privacy requirements of third parties, the requirements set by data protection and other confidentiality considerations must be taken into account when disclosing the results.
The whistleblower’s identity may be revealed if the misconduct results in a criminal procedure or other legal proceedings.
PROCESSING OF PERSONAL DATA
The whistleblowing service may collect personal data of the individual specified in the report, the individual submitting the report (unless submitted anonymously) and potential third parties in relation to the investigation of the suspected misconduct.
The privacy statement concerning the processing of personal data can be found here: https://eezy.fi/en/data-protection/.
5. Legal basis of the activities
The General Data Protection Regulation of the EU and Finnish legislation concerning the processing of personal data are complied with in Eezy’s reporting and investigation of suspected misconduct. We also comply with the EU Whistleblowing Directive and Finnish legislation concerning whistleblowers.
