Whistleblower Policy
Whistleblowing
If you suspect or have knowledge of anything that violates laws or Cactus Rails (Cactus) policies or values, there are several options available to report it.
Cactus values transparency, honesty, and accountability. Employees and business partners have the greatest insight into Cactus’ operations and are therefore important sources for detecting any problems, inaccuracies, or neglect that may violate laws or policies applicable to Cactus’ operations and that may cause harm.
The whistleblowing policy is designed to inform employees and other stakeholders how they can report without the risk of any negative consequences and to ensure a reliable investigation process under the Whistleblower Act – Act (2021:890) on the protection of individuals who report misconduct.
What can be reported through whistleblowing?
Whistleblowing is intended for reporting misconduct and violations that one knows or suspects to violate laws, guidelines, or policies related to Cactus’ operations. It may involve violations affecting individuals’ lives and health, deficiencies in workplace safety, more serious forms of discrimination, harassment, or significant environmental offenses. It is also possible to report conflicts of interest, anticompetitive measures, bribery, financial crime, and other irregularities that may in any way affect Cactus’ reputation, both directly and indirectly. This list above is not exhaustive but should be seen as examples of events to be vigilant about as potential violations.
Whistleblowing should not be used for:
- Negotiations between the organization and its employees, such as salary negotiations or employment contract negotiations.
- Complaints about quality that do not constitute misconduct, such as complaints about product quality not related to irregularities or violations.
- Complaints about issues unrelated to the types of misconduct described earlier in the whistleblowing policy.
- Spreading rumors or disseminating false information not based on facts or suspicions of violations. You do not need to have solid evidence to express a suspicion, as long as it is done in good faith, meaning with the sincere intention to be fair, open, and honest.
Deliberately reporting false information or information intended to harm is abusing the whistleblowing process.
Reporting channels for whistleblowing
In the first instance, known or suspected misconduct should be reported to a manager or to the CEO. If that does not feel right, you can instead report to our whistleblowing function represented by and board member. You can report confidentially and anonymously.
Whistleblowing function – contact person
You can contact the whistleblowing function in writing by email or letter, via telephone or a physical meeting.
Chairman of the Board
Richard Anell
0702-67 30 29
What happens to your report?
The person you choose to report to will take appropriate action to properly handle the situation. Your report will be evaluated, and you will receive feedback confirming that the matter has been received.
If the assessment indicates that there is substance to your report, it will be further reviewed. Depending on the nature of the case, your report may either undergo an internal investigation, be referred to the police or other law enforcement agencies, be referred to an independent auditor, or be subject to further independent review as needed.
As a whistleblower, you are protected
Cactus respects its employees’ opportunities to be anonymous in whistleblowing processes. However, anonymous whistleblowing may complicate the process and the investigation as additional information is sometimes needed. However, the investigator will respect that anonymous reporting is an option and will do their utmost to ensure confidentiality.
The person’s identity will not be disclosed without the person’s permission unless required by law or in subsequent legal proceedings, for example:
- it is absolutely necessary for the proper handling of the report;
- you have given explicit consent in advance;
- it is required by law or in subsequent legal proceedings, or;
- an investigation has found that the report was made in bad faith.
We encourage everyone using the whistleblowing function to be open about their identity to facilitate handling and reporting. All cases will still be treated confidentially as above, as it is expressly forbidden to attempt to identify a whistleblower who wishes to remain anonymous.
As a whistleblower, you are also protected by the principle that reprisals are prohibited. Any negative consequences for you resulting from your good faith reporting of misconduct are considered a serious offense and may for the other party result in sanctions, disciplinary action, or termination of the business relationship. Harassment, bullying, or negative impacts on your career are examples of such negative consequences that are prohibited.
Protection of personal data
Rights of individuals involved in cases in the whistleblowing process are protected under applicable data protection laws. Personal data included in case management and investigation documentation will be erased after completion of the investigation, except in cases where applicable laws