ºÚÁÏÍø

1.0 Who can be a whistleblower?

1.1 You as a whistleblower can be an employee to us or a person having self-employed status, shareholder or person belonging to the administrative, management or supervisory body of an undertaking, as well as a volunteer and paid or unpaid trainee. You as a whistleblower can also be any person working under the supervision and direction of contractors, subcontractors and suppliers to us.

1.2 Please note that you may still be a whistleblower even though our work-based relationship has ended or if it is yet to begin.

2.0 Who is responsible for the Whistleblowing report?

2.1 SITE is responsible if you make a Whistleblowing report pursuant to this policy. As such, SITE has a responsibility to protect you, including not disclosing your identity to anyone beyond the authorised persons that receive your Whistleblowing report (unless you explicitly consent or we are required to disclose you pursuant to law) and making sure you are not subject to retaliation.

2.2 However, please note that you also have a responsibility in this Whistleblowing policy. We expect you to only report information and personal data that is relevant for the handling of a specific Whistleblowing report. We also ask you not to report personal work-related grievances, such as interpersonal conflicts between you and other employees or a decision relating to your employment or engagement. Personal work-related grievances should be raised with the SITE admin director or director.

3. What can be reported in a Whistleblowing report?

3.1 If you acquire information in a work-based relationship with us and have reasonable grounds to believe that there is, in relation to us, misconduct or actual breaches of applicable rules or regulations you are welcome to file a Whistleblowing report on that matter.

3.2 The Whistleblowing Directive particularly specifies the importance of reporting in the following areas: (i) public procurement; (ii) financial services, products and markets, and prevention of money laundering and terrorist financing; (iii) product safety and compliance; (iv) transport safety; (v) protection of the environment; (vi) radiation protection and nuclear safety; (vii) food and feed safety, animal health and welfare; (viii) public health (ix); consumer protection; (x) protection of privacy and personal data; or (y) harassment and unethical conduct, we strongly encourage you to file a Whistleblowing report on that matter.

3.3 Please note that reasonable grounds to believe means that, in light of the circumstances and the information available to you at the time of filing a Whistleblowing report, you believe that the reported matter is true.

4.0 Where can you file a Whistleblowing report?

4.1 We enable you to file a Whistleblowing report in writing via SITE’s website, email or orally to SITE admin director or director. Oral reporting is possible by telephone [or through other voice messaging systems], and, upon request by you, by means of a physical meeting with such designated impartial person or department as specified in the contact details below.

4.2 Filing a Whistleblowing report in writing is possible by using SITE’s external whistleblowing system, Whistlelink. The product is managed by the external party Whistleblowing Solutions AB and is available 24 hours a day. Please file a Whistleblowing report in Whistlelink here:

4.3 We will acknowledge the receipt of the Whistleblowing report from you within seven days of the receipt. For your information, SITE has also designated an impartial person or department competent, see contact details below, for follow-up on the Whistleblowing report, which will maintain communication with you and, where necessary, ask for further information from you and, at the latest three months from the acknowledgement of receipt, provide feedback to you.

4.4 In connection to filing a Whistleblowing report, we would also like to inform you that you can choose to file your Whistleblowing report anonymously. This does not affect your rights and protection in the EU Whistleblowing Directive. However, complete anonymity may make it more difficult for us to investigate the issue or take the action we would like to take.

4.5 Finally, we would also like to clarify that, if you have difficulties or if internal reporting would not be appropriate, it is possible to file a Whistleblowing report externally to competent authorities and, where relevant, to institutions, bodies, offices or agencies of the EU. Contact information can be found

5.0 Personal data

5.1 Our goal is to always protect the personal data we process to the best of our ability. This means that we always undertake to safeguard your privacy and to comply with applicable personal data legislation, including but not limited to the General Data Protection Regulation (GDPR).

5.2 When you file a Whistleblowing report, we will process the personal data contained therein in order to fulfil our legal obligations according to, among other things, the Whistleblowing Directive.

6.0 What are your rights?

6.1 We are committed to implement and maintain necessary and adequate measures in order to prohibit any form of retaliation against you by reason of filing a Whistleblowing report, including threats of retaliation and attempts of retaliation.

6.2 To exemplify further, prohibition against retaliation by reason of filing a Whistleblowing report means, for instance, prohibition against (a) suspension, lay-off, dismissal or equivalent measures; (b) demotion or withholding of promotion; (c) transfer of duties, change of location of place of work, reduction in wages, change in working hours; (d) withholding of training; (e) a negative performance assessment or employment reference; (f) imposition or administering of any disciplinary measure, reprimand or other penalty, including a financial penalty; (g) coercion, intimidation, harassment or ostracism; (h) discrimination, disadvantageous or unfair treatment; (i) failure to convert a temporary employment contract into a permanent one, where you had legitimate expectations that you would be offered permanent employment; (j) failure to renew, or early termination of, a temporary employment contract; (k) harm, including to your reputation, particularly in social media, or financial loss, including loss of business and loss of income; (l) blacklisting on the basis of a sector or industry-wide informal or formal agreement, which may entail that you will not, in the future, find employment in such sector or industry; (m) early termination or cancellation of a contract for goods or services; (n) cancellation of a licence or permit; or (o) psychiatric or medical referrals.

6.3 Please note that, in addition to the information provided in this Whistleblowing policy, the competent authority provides comprehensive and independent information and advice, which is easily accessible and free of charge, on procedures and remedies available, as well as the protection against retaliation, and on the rights you have. Contact information can be found