Whistleblower Policy

At FM Bulk Handling A/S, we strive to promote an open corporate culture where everyone has the opportunity to come forward and report suspected irregularities or unlawful conduct, whether involving employees, management, customers, suppliers, or products.

The whistleblower scheme allows employees to submit anonymous reports in cases of justified suspicion of serious and reprehensible conduct or illegal activities. The scheme ensures that such reports are handled seriously and appropriately and provides reassurance that any person who, in good faith, reports a serious concern will be protected against retaliation and similar consequences. Below is a general description of the matters that may be reported via the portal. The full policy is available on the portal itself.

Which matters can be reported??

The whistleblower scheme may only be used to report serious irregularities or unethical conduct relating to matters that may affect FM Bulk Handling A/S as a whole or individuals’ life and health.
There must be a justified suspicion of breaches of applicable legislation or of FM Bulk Handling A/S’s internal policies and guidelines.

Matters that may be reported via the whistleblower scheme include, for example, justified suspicions of:

Fraud / Financial crime

Financial crime such as embezzlement, bribery, fraud, forgery of documents, theft of goods and equipment, etc
Irregularities related to accounting and auditing.
Breaches of competition law (e.g. price-fixing or exchange of price-sensitive information).

Production – in general

Submission of incorrect or misleading information to public authorities.
Serious threats to the environment and safety.

HR

Physical violence, sexual harassment, and health-related issues.

If you are in doubt as to whether your observation should be reported, you are encouraged to submit a report. Where possible, the report should be documented by attaching relevant documentation in digital form. All reports submitted via the whistleblower scheme are taken seriously and will receive a response.

Matters that should NOT be reported Matters that do not concern breaches of legislation or of FM Bulk Handling A/S’s internal policies and guidelines should not be reported via the whistleblower scheme. This includes, for example, dissatisfaction with salary conditions, cooperation issues, conflicts between colleagues and managers, etc.

Hvordan sker en indberetning via Whistleblowerordningen?

How is a report submitted via the whistleblower scheme? Reports may only be submitted electronically (in both Danish and English) by completing and submitting an online questionnaire, which can be accessed via the following link on FM Bulk Handling A/S’s website: https://fmbulk.whistleportal.net

Reports submitted in bad faith via the whistleblower scheme, e.g. with the intent to harass or harm other employees, may result in sanctions and may have employment-law consequences.

How are reports handled?

All information is treated confidentially and with discretion.

BDO Statsautoriseret Revisionspartnerselskab has been appointed by FM Bulk Handling A/S as data processor. BDO provides and administers the technical solution for the whistleblower scheme.

Reports submitted via the whistleblower portal are accessed by a limited number of trusted employees at BDO, who receive and register the reports and forward them to the management of FM Bulk Handling A/S. If a report concerns the management of FM Bulk Handling A/S, it is forwarded to the Chair of the Board.

How are reported cases processed?

It is possible to submit reports anonymously and follow the case using a 16-digit key code, which is displayed after submission via the whistleblower portal.

Subsequent anonymous communication is possible using the same 16-digit key code.

The communication channel will also be used to communicate any conclusion of the case to the whistleblower, if the whistleblower is anonymous. In such cases, the following deadlines apply in the whistleblower portal:

Acknowledgement of receipt of the report within seven days.
Case processing is carried out as quickly as possible and is generally completed within three months.
A conclusion of the case is communicated to the whistleblower via the anonymous communication channel.
As a general rule, all cases are deleted from the whistleblower portal within 90 days of the reporting date, unless the deadline is manually extended by the recipient.
The whistleblower has access to the case via the whistleblower portal and the 16-digit key code until the case is deleted. However, access is limited to a maximum of one year from the reporting date.

Is the reported person informed?

Unless special and substantial investigative considerations apply, the person concerned by the reported information will be informed of the processing of the case once the report has been received and an investigation has been initiated.