Whistleblowing

What is whistleblowing?

Whistleblowing is to report censurable conditions to a party that can take appropriate action to deal with the problem.

By censurable conditions is meant conditions that are in contravention of legal rules, the group's ethical guidelines or ethical norms, for example conditions that may involve

•     danger to life or health

•     danger to climate or the environment

•     corruption or other forms of economic crime

•     abuse of authority

•     unsatisfactory working environment (e.g. HSE issues, bullying, discrimination)

•     breach of personal data security.

Statements concerning conditions that only apply to the employee's own employment relationship, such as professional disagreements and conditions, shall not be regarded as whistleblowing.

Right and duty to report

Lerøy encourages all its employees to report any censurable conditions, as this could help to remedy such issues.

Employees who are willing to report such issues represent an important resource for Lerøy.

All employees have a duty to report any criminal offences and conditions that represent a risk to life and health.

How to report

An employee that becomes aware of censurable conditions in the workplace must submit notification of this in a suitable manner. A satisfactory notification means that the whistle-blower is in good faith that a censurable condition exists.

Notification takes place using Lerøy's digital notification channel. It is also possible to submit a notification verbally. As a rule, such verbal notification shall be addressed to one's immediate superior. If employees find this difficult, they can contact the superior's superior, their local HR department or their local employee representative/safety delegate. Verbal notifications are recorded in Lerøy's digital notification channel by the person who receives the notification.

Follow-up of notifications received

Notifications received via Lerøy's digital notification channel will first be considered by an independent third party, namely Ernst & Young. Further follow-up will be coordinated by Lerøy's notifications committee.

According to the group's notification procedure, the whistle-blower must receive a reply within 14 days confirming that the notification has been received and providing details about what further action will be taken.

Protection against retaliation

All parties involved in a notification case must be safeguarded. Retaliation against employees who submit notifications is prohibited by law.

Any employees who believe themselves to have suffered retaliation following whistle-blowing must report this via Lerøy's digital notification channel.

Anonymity and confidentiality

Lerøy's digital notification channel allows for anonymous notification. However, openness will normally ensure better case processing and provide a better outcome for all parties involved.

The identity of the whistle-blower and all information linked to a notification will be treated as confidential.