1. The object of the Whistleblowing Policy
Harco Heavy Lifting A/S (the “Harco Heavy Lifting”) wishes to encourage an open dialogue on all issues related to Harco Heavy Lifting’s business methods, compliance with Harco Heavy Lifting’s policies or issues which are considered illegal.
The purpose of Harco Heavy Lifting’s whistleblower system is further to ensure a safe environment in which employees within Harco Heavy Lifting as well as external parties with a work-related con-nection to Harco Heavy Lifting have the confidence to speak out about reprehensible practices without fear of repercussions. Thus, the whistleblower system is intended to contribute to ensuring that serious errors and omissions are detected and to the widest extent possible prevented.
The whistleblower system is a supplement to the direct and daily communication at the workplace regarding errors and unsatisfactory conditions, etc
Reports are filed electronically through the whistleblower system via a web portal, Safe2Whistle, which may be accessed via the following link: WhistleB, Whistleblowing Centre.
2. Who can report and where?
The following group of persons are comprised by the whistleblowing system and can as such make a report to the system:
- All employees at Harco Heavy Lifting as well as members of Harco Heavy Lifting’s man-agement board and members of the board of directors.
- Any external parties with a work-related connection to Harco Heavy Lifting, such as con-tracting parties, sub-suppliers and suppliers as well as persons working under the supervi-sion and management of contracting parties, sub-suppliers and suppliers.
3. What to report
The whistleblowing system is solely for the reporting of serious violations subject to the Danish Whistleblower Protection Act. Thus, you may file a report to Harco Heavy Lifting’s whistleblowing system regarding
- violations of specific areas of the EU law
- serious offences and other serious matters
In regard to violations of specific areas of the EU law, you may e.g., file a report regarding
- Violations regarding EU law concerning product safety and compliance. For the remaining areas of relevant EU law, reference is made to article 2 of the EU Directive (EU) 2019/1937 of 23 October 2019 on the protection of persons who report breaches of Un-ion law.
By other serious offences and other serious matters, reports may e.g., concern
- Punishable offences, e.g., abuse of funds, theft, fraudulent misrepresentation, embezzle-ment, fraud, bribery, etc.
- Serious or repeated violations of legislation, including e.g., the Danish Working Environ-ment Act.
- Serious or repeated violations of material internal guidelines, e.g., on business trips, gifts, financial reporting, etc.
- Serious workplace conflicts, e.g., in the form of sexual harassment or other serious har-assment.
The whistleblower system cannot, in general, be used for expressing dissatisfaction with salary levels, minor offences such as violations of guidelines regarding smoking and drinking of alcohol and less serious workplace conflicts and disagreements.
4. How to report
If you file a report, the information listed below will generally be useful in connection with further investigation of the issue:
- A description of the issue in question, including date, place, and the name(s) of the per-son(s) involved
- Any documentation or evidence concerning the violation or other information which may assist the investigation
It is up to you whether you want to file the report in your own name or anonymously.
If you choose anonymity, it is important that you do not state your name anywhere in the report. In addition, you should be aware that your identity might be inferred from the information you have provided in the report.
5. How we handle the issue
As mentioned above, reports to the whistleblowing system can be made electronically via a web portal, Safe2Whislte, which is accessible via the internet.
Bech-Bruun is the data processor for purposes of managing the whistleblower system. The pur-pose of using an external party is to ensure impartiality and objectivity in the processing of the reports.
As external administrator of the whistleblowing system, Bech-Bruun, receives all reports and will begin by filtering out the reports that do not fall within the scope of the system, cf. clause 3. Fil-tered out reports are to be processed through the ordinary channels of communication. You will in this regard be encouraged to direct your report to a relevant person, e.g., your immediate manag-er or your manager’s superior.
Reports falling within the scope and purpose of the whistleblower system will be forwarded to Har-co Heavy Lifting’s whistleblower unit, who will process and investigate the report. Currently, the whistleblower unit consists of Camilla Ankersen, Head of HR together with Mikael Karstensen, HSEQ Manager. Bech-Bruun will be notified about the outcome of the investigation and will as-sess whether the matter may be considered as closed, or whether the report should give rise to additional investigations.
Reports concerning a member of Harco Heavy Lifting’s whistleblower unit will be processed by Bech-Bruun in collaboration with the remaining members of the whistleblower unit who are not disqualified in regard to investigate the specific case.
Reports concerning the management board or members of the board of directors will be pro-cessed by Bech Bruun in collaboration with the chairman of the board of directors.
Reports concerning the chairman of the board of directors will be processed by Bech-Bruun in collaboration with two members of the board of directors who are not disqualified in the relevant case.
No later than 7 days after your report has been received in the whistleblowing system, you will receive confirmation of the receival of your report. As a main rule, you will receive a notification concerning the closure of your report no later than 3 months from receiving this confirmation. If the processing of your report requires longer than 3 months, you will receive a notification regarding the reason why further investigation time is necessary. You will as a main rule, within the limits of Danish legislation, receive information about the outcome of your report.
All communication between you and Bech-Bruun will take place over the whistleblower portal. Thus, it is important that you follow your report on the whistleblower portal if you want to receive confirmation of receipt of your report, a reason for why your report require longer processing time and if you want to receive a notification about the outcome of the investigations of your report.
6. Protection of the whistleblower
Harco Heavy Lifting does not tolerate harassment, vengeful actions or other types of sanctions against any person who in good faith files a report.
Even though you have not made an anonymous report, your identity will be kept confidential to the extent possible, considering Harco Heavy Lifting’s need to make a thorough investigation. However, it may be necessary to disclose information about your identity, for instance if the issue is reported to the police. In such case you will receive information beforehand.
You may not knowingly report incorrect or misleading information through the whistleblower sys-tem. Persons who report in bad faith are not protected by this whistleblowing policy and may be subject to employment law sanctions, including possible dismissal.
7. Duty of confidentiality
Bech-Bruun is together with Harco Heavy Lifting’s whistleblower unit subject to a special duty of confidentiality. Further, any person who is involved in the investigations of a report will be subject to the same special duty of confidentiality in regard to any information that has or is subject of the investigation of the report received through the whistleblowing system.
8. Notice to the reported person and to other persons
If information about you is reported in the whistleblower portal, and the report falls within Harco Heavy Lifting’s whistleblower system, you will as a general rule, not receive any information about the processing of your personal data.
If, on the other hand, the report does not fall within Harco Heavy Lifting’s whistleblower system, you will be informed of the processing of your personal data in accordance with the rules of the Data Protection Regulation and the Danish Data Protection Act.
9. Data protection
The processing of personal data in connection with a report received in the whistleblowing system will be on the basis of section 22 of the Danish Whistleblower Protection Act, according to which processing of personal data subject to articles 6, 9 and 10 of the General Data Protection Regula-tion may take place if the processing of the personal data is necessary to investigate a report re-ceived in the whistleblowing system established in accordance with the Danish Whistleblower Pro-tection Act.
The General Data Protection Regulation and the Danish Data Protection Act will apply to any fur-ther processing of personal data in the whistleblower system.
Harco Heavy Lifting A/S, 41034149 is the data controller for purposes of managing the whistle-blower system.
For further information with regard to the processing of personal data please refer to the Privacy Policy for employees Privacy Policy | HARCO Heavy Lifting A/S and the Privacy Policy for externals Privacy Policy | HARCO Heavy Lifting A/S.
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Please contact Lise Lauridsen +45 7227 3635, Bech-Bruun, if you have any questions about the Whistleblowing Policy.
You may also file a complaint with the Danish Data Protection Agency (Datatilsynet), Carl Jacob-sens Vej 35, 2500 Valby.
If you do not feel safe using Harco Heavy Lifting’s whistleblowing system, or due to other reason feel safer using and external whistleblowing system, you may file a report via the Danish Data Pro-tection Agency’s external whistleblowing system, in which you may file a report either in writing or orally. The Danish Data Protection Agency’s whistleblowing system is available via
