Whistleblower policy

The purpose of the Ornestation Mors Whistleblower scheme is to ensure a safe environment for employees and others connected to the boar station to speak about objectionable conditions at the boar station without fear of negative consequences.

1.The purpose of the whistleblower scheme:

At Ornestation Mors, we want to stand for openness and responsibility in everything we do, just as we want to promote an open culture based on dialogue. Everyone must be able to express themselves freely, and so that there are no obstacles in the way of this, we have established a whistleblower scheme.

A whistleblower scheme is a safe and anonymous opportunity for employees and business partners to draw attention to a suspicion that irregularities or illegalities are taking place at Ornestation Mors.

2. Who ca make a report?

All employees at Ornestation Mors, including management boards, boards and others connected to Ornestation Mors in the form of suppliers, business partners, accountants, lawyers and former employees can use the whistleblower scheme.

3. How is reporting done?

Reports can be made by accessing the whistleblower scheme on our website. Our system informs and guides the reporter about matters of importance for the assessment of the report.

If you make a report, the following information will normally be useful in the further investigation of the case:

Description of the relationship, including date, place and the name(s) of the person(s) involved as well as any documents or evidence relating to the violation or other information that may facilitate an investigation of the matter.

You choose whether you submit the report in your own name or anonymously. If you want anonymity, it is important that you do not write your name anywhere in the report. In addition, you should be aware that it cannot be ruled out that your identity can be deduced from the information you have provided yourself in the report. If legal proceedings are initiated against the reported person, you may be called as a witness in the legal proceedings, whereby anonymity may be lost.

Ornestation Mors may be obliged to make the report available to persons who are affected by it or by the measures it may give rise to.

4. What you can report on?

You can use the reporting system to report any serious matter that falls within the scope of the rules on whistleblower protection in force at any given time. It can, for example, be suspicion or knowledge of illegal, unethical or unregulated behaviour, including matters relating to nepotism, bribery and corruption, fraud, economic crime, breach of personal data security, serious damage to the environment, conflicts of interest, sexual harassment or other serious harassment as well as gross or repeated breaches of legislation Moreover.

In each case, we will carry out a concrete assessment of whether the report falls within the scheme's scope of application. The report will fall within the scope of application of the scheme if it falls within the scope of application of the regulations applicable at any time on the protection of whistleblowers.

If you are an employee, we would like to draw your attention to the fact that, as a clear starting point, dissatisfaction with your employment relationship such as salary and management style and other contractual terms should not be reported in the whistleblower scheme. Such conditions must instead be addressed through the normal channels, e.g. to immediate supervisor.

Reports must be made in good faith. This means in particular that the scheme must not be used to report deliberately incorrect information.

5. Handling of reports

The whistleblower unit consists per 1 March 2023 by Director Johnny Markussen and Chairman of the Board Anders Borg.

When the unit has screened your report, you will receive a receipt for receipt of the report as soon as possible and at the latest within 7 days. If you report anonymously, we do not have the option of this.

During the screening, the whistleblower unit makes an assessment of the report. The report will then be made the subject of an investigation, the extent of which depends on the specific circumstances of the case. The further investigation will basically be carried out by the whistleblower unit.

If the initial screening shows that the report is not covered by Ornestation Mor's whistleblower scheme, the report will not be processed further in the scheme, and the reporter will be informed of this. If you report anonymously, we do not have the option of this.

The reporting party will receive feedback on the status of the case within three months, including what kind of follow-up on the report has been carried out, if any.

6. Protection of the personmaking the report (the whistleblower) and Anonymity

The reporter is free to choose whether he wants to make a report anonymously or with his personal contact details.

If the reporter chooses to make a report anonymously, neither Ornestation Mors nor a third party will generally process personal data about the reporter. If, in connection with his report, the reporting party provides information that enables Ornestation Mors to identify the person concerned, Ornestation Mors will, however, be entitled to process this information. This applies regardless of whether the reporting party has otherwise made the report anonymously.

In the case of an anonymous report, the reporter will not have the opportunity to choose whether he or she will be available for any further investigation. Ornestation Mors encourages the reporter not to be anonymous, as it may be difficult for Ornestation Mors to carry out an investigation without further information from the reporter.

If the reporter chooses to reveal his identity in connection with a report that is covered by the scheme, Ornestation Mor's whistleblower unit has a duty of confidentiality regarding the reporter's identity in accordance with the applicable rules on the protection of whistleblowers. The reporting party's identity will thus, as a rule, only be passed on if the reporting party expressly consents to this. However, the reporting party's identity can also be passed on to public authorities, e.g. police or prosecuting authority, if necessary to address reported matters or in order to ensure the right of affected persons to a defence.

A reporter who reports serious matters covered by Ornestation Mor's whistleblower scheme cannot face reprisals of any kind as a result of the report.

The reporting system does not log either the IP address or the machine ID of the computer from which the report is made, and the system does not use cookies. If the computer from which the report is made is owned by Ornestation Mors or connected to Ornestation Mors' network, there is a risk that it will be logged in the browser's history/or Ornestation Mors' log, which IP address and/or which machine The ID report is made from, via the logging that takes place in Ornestation Mor's IT systems. The reporter can eliminate this risk by making the report from a computer that is not owned by Ornestation Mors or connected to Ornestation Mors' network.

Ornestation Mors does not tolerate harassment, retaliation against or other forms of sanctions against persons who in good faith report a case in the whistleblower scheme, and this will therefore be met with employment law consequences.

You must not knowingly submit false or misleading information that casts suspicion on innocent persons. Reports made in bad faith may, depending on the circumstances, have negative employment law consequences for the person who made the report.

7. Reporting to external reporting channels

The reporter will also be able to report to an external reporting channel – i.e. a whistleblower scheme administered by a public authority. Thus, e.g. The Data Protection Authority in Denmark created an external reporting channel which supplements employers' obligation to set up whistleblower schemes. Reporting to external reporting channels is not conditional on prior reporting to Ornestation Mors' whistleblower scheme. However, we encourage you to send your report to Ornestation Mor's whistleblower scheme, so that Ornestation Mor's whistleblower unit can quickly and immediately follow up on the reported matter.

8. Confidentiality

Ornestation Mor's whistleblower unit and the persons who may be involved in the investigation of the report are subject to a special statutory duty of confidentiality with regard to the information that is or has been the subject of processing in the whistleblower scheme.

The unit will ensure that this special duty of confidentiality is tightened towards the persons who are involved in the processing and investigations of a report.

9. Data protection, privacy policy and fulfillment of the obligation to provide information

1. Purpose of processing personal data in the whistleblower scheme

The purpose of the processing of personal data in Ornestation Mors' whistleblower scheme is to uncover knowledge of serious matters, including suspicion or knowledge of illegal, unethical or unregulated behaviour, with a view to preventing, containing and following up on such matters throughout the organisation.

Ornestation Mors is the data controller for the personal data processed in the whistleblower scheme. The information comes from the circle that can report to the scheme, i.e. Ornestation Mor's employees as well as customers, suppliers and other business partners.

2. Categories of personal data processed

A report may contain personal data about the reporting person (the whistleblower). Reports may also contain general and sensitive personal data relating to the person or persons, if any, being reported on (those affected), just as it may contain information about other persons.

The collected information can e.g. concern name, position and any other information about the person or persons concerned. A report will typically contain information about the specific serious matter that is being reported and how the possibly affected person is said to be involved in it.

A report can include documents in the broadest sense, including text, image and video material.

All personal data collected through the scheme will be treated confidentially to the greatest extent possible.

3. Basis of treatment

Processing of personal data in the whistleblower scheme is necessary to be able to investigate and prevent serious conditions at Ornestation Mors. Processing of information in the whistleblower scheme is thus necessary for Ornestation Mors to pursue a legitimate interest which is assessed as a starting point to take precedence over the data subject's interest in protecting the personal data in question, cf. the data protection regulation, article 6, subsection 1, letter f.

Information about criminal offences, including suspected criminal offences, will only be processed if the processing is authorized by EU law or the national law of the Member States, which provides adequate guarantees for the rights and freedoms of data subjects, cf. Article 10 of the Data Protection Regulation.

In some cases, a report will contain sensitive personal data, e.g. trade union affiliation, political beliefs, religious beliefs, health information, sexual relationships and biometric data.

Such information is only processed if the processing, in addition to pursuing a legitimate interest, cf. above, is lawful pursuant to Article 9 of the Data Protection Regulation. Processing of sensitive personal data will e.g. be lawful if it is necessary for legal claims to be established, asserted or defended, or when courts are acting in their judicial capacity.

For example, sensitive personal data will also be able to be processed when it is necessary to comply with the labor, health and social law obligations and specific rights of Ornestation Mors or affected persons, insofar as it is based on applicable legislation or a collective agreement that provides the necessary guarantees for the fundamental rights and interests of the reported person(s).

It is noted that all categories of personal data that are processed in connection with reports are only stored for as long as is necessary for the investigation of the reported matter and the further process, cf. 5.

4. Rights

4.1 Notification

If the report concerns one or more named persons, the person or persons concerned will, as a starting point, receive notification of:

The subject of the reported relationship
The outcome of the report, including whether the report has been rejected as unfounded or made the subject of further investigation
The legal basis for the processing of the person concerned's personal data, as well as other information that must be provided pursuant to the Personal Data Act
Which persons in Ornestation Mors are aware of the report or will possibly become aware of it
The intended period of time for which the personal data will be stored, or alternatively the criteria used to determine this period of time
How the person concerned can exercise his right of objection and rectification to familiarize himself with and respond to the report

The notification is made as soon as possible and no later than 14 days after the above information has been obtained.

If the personal data must remain confidential as a result of confidentiality obligations under the Member States' national law, including statutory confidentiality obligations, notification may be omitted after a specific assessment, cf. the data protection regulation's article 14, subsection 5, letter d.

If there is a concrete risk that the notification will jeopardize the investigation of the reported matter or the possibility of obtaining the necessary evidence, the notification may be postponed or omitted until the risk no longer exists in accordance with the rules of Article 23 of the Data Protection Regulation and national implementation of these rules.

If the report contains information about identifiable persons other than the person to whom the report relates, these persons will be notified as described above. This notification must not contain identifiable information about the person concerned

4.2 Rights catalog

When Ornestation Mors has registered a reported person and possibly information about the reporting person or other persons mentioned in the report, the persons concerned have the right to gain insight into the personal data that is processed about them.

If the relevant request for access is made, Ornestation Mors will therefore, among other things, inform the person concerned about:

the purpose of the processing of the information
what type of personal data is processed about the person concerned
the right to request Ornestation Mors to correct or delete personal data or limit the processing of personal data that is processed about the person concerned or to object to the processing, and
any available information about where the processed personal data originates from, however not information about the reporting party if the latter has reported in good faith.

The right of access only applies in relation to personal data that is processed about the person concerned. No claim can be made to gain insight into information that only concerns other persons. The right of access does not apply if the person concerned's interest in having the information about himself handed over is found to give way to significant considerations of public or private interests in accordance with the rules in Article 23 of the data protection regulation and national implementation of these rules.

The person concerned also has the right to object to the processing of information and to request that information be corrected, limited or deleted in accordance with the personal data legislation in force at any time

5. Storage and deletion of personal data

Personal information that is processed in connection with reports is stored for as long as is necessary for the investigation of the reported matter and the further course of action.

If the initial screening of the reported matter shows that the report is not covered by Ornestation Mor's whistleblower scheme, or that there is no proof of the reported matter, Ornestation Mor deletes the report and the personal data contained therein as soon as possible and no later than three months after the end of the initial screening.

If the initial screening of the reported matter shows that it is not unlikely that the reported matter has taken place, Ornestation Mors will initiate a thorough investigation and delete the report and the personal data contained therein at the earliest when the investigation has been completed.

6. Transfer and disclosure of personal data

As a rule, Ornestation Mors does not pass on personal data collected via the whistleblower scheme to third parties.

The following types of disclosure will, however, be possible after a specific assessment:

Disclosure to external advisers, e.g. lawyer or accountant with a view to further investigation of the matters reported
Transfer to relevant authorities, including the police and public prosecutor's office, for the purpose of possible prosecution
Disclosure that otherwise follows from requirements in legislation

7. Complaint

You have the right to lodge a complaint with the Danish Data Protection Authority if you are dissatisfied with the way we process your personal data. You will find the Data Protection Authority's contact information at www.datatilsynet.dk.

8. Contact Information

Questions about your rights etc. in connection with the processing of personal data in the scheme, please address to:

Ornestation Mors

Gl. Møllevej 97

DK-7970 Redsted

CVR-nr.: 15692987

Tel + 45 9776 2133

E-mail: info@ornestationmors.dk