Whistleblowing channel

At Castrén & Snellman, our daily work is guided by our values: The Spark, Respect, Courage and Responsibility. Our Code of Conduct, based on these values, sets the ground rules for our dealings with each other, our clients and the society at large. It is inspired by the UN Global Compact and other international standards on corporate responsibility.

We nurture a culture of openness and honesty – report any misconduct or concerns

Unethical, unlawful or irresponsible actions can cause serious harm to a company’s reputation and to its employees, clients and stakeholders. This is why it is everyone’s responsibility to act as a whistleblower if they observe misconduct or unethical behaviour. We encourage our experts to always turn to their supervisor, HR or senior management with any concerns. Alternatively, they can use the anonymous and confidential whistleblowing channel. Our external partners can also use the whistleblowing channel to report any suspected misconduct.

What is a whistleblowing channel?

The newinnish Whistleblower Protection Act, based on the EU Whistleblower Directive, requires all private and public organisations with at least 50 employees to have a confidential internal reporting channel through which employees and stakeholders can report any misconduct in the organisation.

At Castrén & Snellman, our experts and external stakeholders can report misconduct and unethical behaviour anonymously through a system provided by Granite Partners Ltd. Whistleblowers can file a written report in the system using Finnish or English.

Which matters can be reported through the whistleblowing channel?

Whistleblowers can report activities that they suspect to be unlawful or otherwise unethical. According to the law, misconduct related to e.g. the following areas can be reported through the whistleblowing channel:

• protection of privacy and personal data
  
• security of network and information systems
  
• protection of the environment
  
• public health
  
• consumer protection
  
• public procurement
  
• financial services, products and markets
  
• prevention of money laundering and terrorist financing
  
• product safety and compliance.
  

The new Whistleblower Protection Act does not apply to all reporting. This is because section 4 of the Act on the Protection of Privacy in Working Life requires that personal data concerning employees are collected primarily from the employees themselves. Collecting data through other means, such as through a whistleblowing channel, requires consent by the employee in question unless the law specifically allows for such data collection. Therefore matters related to discrimination or harassment cannot be reported through this channel as the new act does not list these as reportable matters.

What happens after reporting?

We investigate and handle all reports received through the whistleblowing channel confidentially and take appropriate action based on the results of the investigation. Only the approved handlers can access the reports. Whistleblowers do not need to have comprehensive evidence to support their suspicions, but all reports must be honest and sincere. Reports should contain all the available information in as much detail as possible so that the matter can be looked into.

Whistleblowers can file reports completely anonymously or include their contact information if they wish to do so. The law protects whistleblowers against all retaliation, which means that reports can be made without fear of negative consequences.

If needed, the handlers can request additional information from the whistleblower or consult other experts. However, confidentiality is never compromised. The Granite system does not store whistleblowers’ IP address or any other identifying data. The system has rigorous data security and data protection controls to ensure confidentiality.

The handler will inform the whistleblower of the measures already taken and planned based on the report within three months.

To report misconduct, please visit this site.