Whistleblower scheme

The Alumeco Group’s whistleblower scheme gives employees and external partners related to Alumeco the opportunity to report concerns and reasonable suspicions about irregularities or violations of rules committed or likely to be committed by Alumeco’ s employees, Management, Directors etc.

We strongly encourage you to speak up if you suspect or witness any matters of concern. Alumeco will handle all reports made under our whistleblower scheme seriously.

Please read down below before reporting your suspicion or concern.

Who can use the whistleblower scheme?

You can submit a report if you are a current or former employee of Alumeco, a supplier or a business partner with a connection to the Alumeco Group.

What may the report relate to?

You can report through the whistleblower scheme if you have knowledge or suspicion of illegal activities or serious irregularities in Alumeco such as breaches of applicable laws and regulations or other serious matters, including breaches of EU law as set forth in the Directive of the European Parliament and of the Council on the protection of persons who report breaches of Union law, including (but not limited to) the following:

• Criminal offences, including fraud, embezzlement, misuse of assets, forgery of documents, accounting manipulation, bribery, corruption and money laundering
• Competition law breaches
• Serious or repeated breaches of occupational health and safety legislation
• Significant breaches of environmental regulations and pollution of the environment
• Breach of professional secrecy
• Serious or repeated breaches of important internal guidelines in Alumeco
• Serious workplace conflicts, such as severe bullying, harassment, discrimination, physical violence, threats and sexual abuse

What cannot be reported trough the whistleblower scheme

Other matters, including HR matters, complaints about other employees’ behavior or incompetence, dissatisfaction with salary conditions, including minor breaches of Alumeco’ s internal guidelines on sick leave, alcohol intake etc. are not covered by the scope of the whistleblower scheme. These types of matters must be raised in a dialogue with an intermediate manager or the HR department who has the duty of confidentiality. 

PwC and The Whistleblower Committee in Alumeco

Our whistleblower scheme is operated by an external third party, PwC (PwC Statsautoriseret Revisionspartnerselskab "PwC"). PwC is an independent audit, tax and advisory firm, who receives reports on behalf of Alumeco to ensure an independent and anonymous channel.

The Whistleblower Committee is the overall unit responsible for the whistleblower scheme in Alumeco.

Confidentiality, objectivity and anonymity

You have the right to submit the report anonymously. If so, do not disclose your name or any other personally identifiable information, such as your address, email or telephone number.

If you choose to remain anonymous, you should know that it may complicate the investigation of your concern or suspicion. We therefore encourage you to disclose your identity when making a report in the knowledge that you can do so without having to fear intimidation, harassment, retaliation, reprisals, discrimination, or adverse employment consequences because of such report.

If you decide to disclose your identity to PwC, your identity will only be known to PwC. Your identity will be kept anonymous and not disclosed to Alumeco unless you give explicit consent to disclose it to Alumeco.

How is your report handled?

PwC will confirm the receipt of the report directly to you within seven days of receiving your report, if possible.

If the report does not fall within the scope of the whistleblower scheme, it will be forwarded to Alumeco with a notice to this effect. Consequently, as there is no basis for processing the report, it will immediately be deleted.

If the report falls within the scope of the whistleblower scheme and there is a basis for conducting an investigation, PwC will forward the report to The Whistleblower Committee in Alumeco, who will determine the appropriate steps to take and whether an investigation of the matter will be initiated.

Personal data

Personal data and information submitted through the whistleblower scheme are processed for the purpose of establishing your report of potential criminal offences and/or irregularities of major concern to Alumeco.

The legal basis for investigating any unethical and/or illegal conduct or activity, irregularities, wrongdoing or dangers at work in Alumeco, so that Alumeco can prevent and avert illegal and serious conduct and activities and for the processing of personal data, follows from Regulation (EU) 2016/679 (“GDPR”):

• Article 6 (1) on the processing of personal data
• Article 9 (2) on the processing of special categories of personal data
• Article 10 on personal data relating to criminal convictions and offences

processing of personal data which is necessary for Alumeco to pursue a legitimate interest in being able to investigate any criminal offenses or other unlawful conduct in the whistleblower reports.

Alumeco collects and processes personal data for the purpose of pursuing the legitimate interest of Alumeco in ensuring compliance with applicable laws throughout all of Alumeco’s operations. This is in accordance with point f in Article 6 (1) under the GDPR.

Alumeco collects and processes personal data about you for the purpose of complying with legal requirements in order to meet a legal obligation imposed by law, by regulation and/or national rules specific for the reported matter. This is in accordance with point c in Article 6 (1) under the GDPR.

Alumeco collects and processes the following personal data in accordance with the outlined purpose and legal basis:

• Information regarding the reported matter - potential breach of law, criminal offence, violations of internal policies, procedures and guidelines in Alumeco or other serious matters
• Documents, information or evidence supporting the reported matter, and other information relevant to the investigation of the matter
• The whistleblower’s name, e-mail and telephone number, including other potential identifiable personal information
• Names of any persons mentioned in the whistleblower report, including other potential identifiable personal information, and names of persons within Alumeco or outside Alumeco who know or may know about the reported matter

When your personal data is registered, you have the right to submit a complaint with the relevant independent authority that supervises compliance with the rules on protection of personal data. You can access a complete list of European supervisory authorities here.  

Reference is made to Alumeco’s data privacy policy, which deals with the processing of your personal data and your rights. You can find it here.

Whistleblower protection

Alumeco does not tolerate harassment and retaliation against whistleblowers. No whistleblower will be victimized for raising a matter through the whistleblower scheme as long as the concern was raised in good faith.

Alumeco does not accept that an employee intentionally submits incorrect or misleading information via the whistleblower scheme. If an employee knowingly makes a false report, it may result in negative employment law consequences, including termination of employment.

Submit a report

You can submit your report through the whistleblower scheme here.