Whistleblower Policy


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 

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