Whistleblowing

Springvest strives to maintain an open and trustworthy business environment and high standards of business ethics. Our whistleblowing service makes it possible to report suspected misconduct in the organisation confidentially.

It is an important tool for reducing risk and maintaining trust, as it helps us detect possible misconduct and act on it at an early stage.

Anyone can make a whistleblowing report, either openly or anonymously.

Our whistleblowing service can help us become aware of serious risks affecting individuals, the company, society or the environment. It handles information on serious misconduct relating to:

• accounting, internal accounting controls, auditing, anti-bribery, and banking and financial crime, or
• other serious breaches relating to the company’s vital interests or to the life or health of individuals, such as serious environmental crimes, major deficiencies in workplace safety and very serious discrimination or harassment.

If the matter concerns dissatisfaction in the workplace or misconduct relating to some other matter, please contact your manager or Springvest’s compliance officer, as these matters cannot be investigated through the whistleblowing process.
You do not need firm evidence of misconduct before reporting a suspicion. However, reports should be made honestly and in good faith. Misuse of the whistleblowing service is a serious offence.

You can raise a concern in different ways:

Option 1 (employees) – report to your own manager

Employees should primarily contact their own manager about suspicions relating to the company.

Option 2 (employees) – report to other management or the compliance officer

Employees can report the matter to other members of the company’s management or to the compliance officer if they prefer, or if the suspicion concerns their manager.

Option 3 (stakeholders) – report to the compliance officer

Stakeholders can contact the company’s compliance officer at compliance@springvest.fi.

Option 4 (employees and stakeholders) – report through the reporting channel

Report confidentially to the whistleblowing team, anonymously or in your own name, through the WhistleB reporting channel.

We encourage everyone who reports a suspicion to disclose their identity. All reports received are handled confidentially.

If you wish to remain anonymous, however, you can make an anonymous report.

The whistleblowing channel that allows anonymous reporting is managed by an external service provider, WhistleB (by Navex). All messages are encrypted.

WhistleB protects the anonymity of the person submitting a report by removing all metadata, such as IP addresses. The reporter also remains anonymous in any follow-up dialogue with those handling the report.

Whistleblowing team

Only designated members of the whistleblowing team have access to reports made through Springvest’s reporting channel. Their actions are logged, and all activities are confidential. During the investigation, the team may request information and expertise from other people as it considers necessary. These people have access to the information relevant to the investigation and are also bound by confidentiality.
If someone reports a suspicion of misconduct directly to a manager or to the whistleblowing team in their own name, the report is handled in accordance with these guidelines. Springvest’s whistleblowing team consists of the

• compliance officer
• General Counsel.

Receiving a report

On receiving a report, the whistleblowing team decides whether to accept or reject it. If the report is accepted, appropriate steps are taken to investigate it. See Investigation below.

The whistleblowing team may reject a report if

• the alleged misconduct is not a reportable matter under the whistleblowing policy
• the report has not been made in good faith or is malicious
• there is not enough information to allow further investigation
• the matter raised in the report has already been resolved.

If a report includes matters outside the scope of the whistleblowing guidelines, the whistleblowing team must take appropriate action to resolve the issue.

The whistleblowing team sends an acknowledgement of receipt within seven (7) days of the report and provides feedback within three (3) months of the date the report was received.

Do not include sensitive information about any individual in your report unless it is necessary to describe your concern.

Investigation

All reports are taken seriously and handled in accordance with these whistleblowing guidelines.

• No attempt is made to identify the reporter.
• Where necessary, the whistleblowing team asks follow-up questions through the anonymous reporting channel.
• No one who is the subject of the suspicion, or connected to it, takes part in the investigation.
• All reports are handled confidentially.

Protection of the reporter in non-anonymous reports

A person who raises a genuine concern will not risk losing their job or suffer any sanctions or personal disadvantage as a result of the report. It does not matter if the reporter is mistaken, provided they acted in good faith.

Where appropriate, a non-anonymous reporter is informed of the outcome of the investigation into the allegations, while respecting the privacy of the people against whom allegations have been made and other confidentiality considerations.
If criminal charges are brought, the reporter is informed that their identity may need to be disclosed in legal proceedings.

Processing of personal data

The reporting service may collect personal data on the person named in a report, on the person submitting the report (unless the report is submitted anonymously) and on any third parties, in order to investigate suspected misconduct and inappropriate behaviour that breaches our ethical guidelines or internal rules.

This processing is based on the legitimate interest of preventing reputational risks and promoting ethical business.

The report and the facts subject to this processing are seen only by an authorised person, who handles the information confidentially. Data subjects have the right to access information about themselves and to request corrections or deletion if the information is inaccurate, incomplete or out of date, in accordance with local data protection legislation.

These rights may be restricted by overriding safeguards designed to prevent the destruction of evidence or any other obstruction of the investigation and handling of the case.

If you have any questions or wish to make a complaint, please send your request to info@springvest.fi.

Deletion of data

Personal data contained in whistleblowing reports and investigation documents is deleted when the investigation is complete, unless retention is required under other applicable laws. The data is permanently deleted five (5) years after the investigation is completed.

Archived investigation documents and reports made through the reporting channel must be anonymised in accordance with the General Data Protection Regulation (GDPR) and must not contain personal data from which a person can be identified directly or indirectly.

This policy is based on the EU General Data Protection Regulation, the EU Whistleblower Protection Directive and national whistleblowing legislation.

Data is stored within the EU. Transfers of personal data outside the European Economic Area (EEA) are generally prohibited unless specific measures are taken to protect the data.

Data controller

Springvest Corporation, Siltasaarenkatu 8–10, 00530 Helsinki, Finland

Data processor

WhistleB Whistleblowing Centre AB (World Trade Centre, Klarabergsviadukten 70, SE-111 64 Stockholm, Sweden) is responsible for the reporting channel application, including the processing of encrypted data such as reports.
Neither WhistleB nor its subcontractors can decrypt messages or read reports. This means that WhistleB and its subcontractors have no access to readable content.

• Questions and answers (WhistleB website) 
• How do I send a message? Watch a short instructional video on the WhistleB website.
• If you have any questions, please get in touch.

Springvest Corporation
Address: Siltasaarenkatu 8–10, 00530 Helsinki, Finland
Phone: +358 9 315 46989
Email: info@springvest.fi
Business ID 2492165-6