Elomatic reporting channel and reporting instructions
Elomatic nurture open culture and strict ethics in their operations. The company is committed to maintaining a conversation-oriented organisational culture in which anyone can report their suspicions of actions that go against the public interest without the risk of becoming a victim, a target of discrimination or ending up in an unfavourable position.
Elomatic consider it vitally important that anyone can immediately report any and all suspected or observed cases of activity that go against the public interest.
The purpose of these reporting instructions is to encourage people to report all potential activity that goes against the public interest and to ensure that the reports are processed appropriately.
The national enforcement of the directive (EU) 2019/1937 on the protection of persons who report breaches of European Union law, the so-called Whistleblower directive, is being prepared by the Ministry of Justice and the Ministry of Economic Affairs and Employment. The objective of the new legislation is to ensure that a person who, in their work, notices or suspects activity that goes against the public interest in the separately determined national or EU sectors of justice, can safely report the issue.
The objectives of the Whistleblower directive and national legislation include
- creating uniform minimum requirements for the protection of whistleblowers in both the public and private sectors within the EU, and
- creating effective protection for whistleblowers who, in their work, notice the breach of national or EU regulations in things such as public procurements, financial services, foodstuff safety or consumer protection.
The scope of application of the directive and national legislation also includes
- fraud, corruption and other such illegal activity related to the realisation of the EU’s costs or the collection of the EU’s income and assets,
- infringements that relate to the EU’s internal market, such as infringements of the EU’s competition rules and government support rules,
- infringements that relate to the internal market to the extent the infringement concerns actions that violate corporation tax rules or arrangements that aim to obtain tax benefit contrary to the objective or purpose of the applicable corporate tax rule, and
- infringements that result in a threat to public interest or that result in a severe threat to the public interest if its consequences include considerable risks for the wellbeing of society.
According to the directive, there must be a way to report misconduct safely and so that the identity of the whistleblower is protected. Furthermore, taking countermeasures against a whistleblower as a result of their actions is prohibited. Violating the ban on countermeasures or preventing the filing of the report can result in liability for damages and the obligation to pay compensation to the whistleblower.
A Government initiative for legislation concerning the protection of persons reporting a violation of the European Union’s law or national law and the laws related to it is supposed to be presented to Parliament in February 2022. Further information about the progress of the initiative can be found at: National enforcement of the Whistleblower directive (eduskunta.fi) (in Finnish)
When to file a report?
For the purpose of reporting, Elomatic have procured a reporting channel service provided by the Central Chamber of Commerce.
The reporting channel gives everyone the opportunity to report suspected cases of activity that goes against the public interest of Elomatic.
In the reporting channel, the report can be filed either anonymously or under the whistleblower’s name. The reporting procedure is encrypted and password-protected. All reports are processed in strict confidence.
If you notice or suspect activity that goes against the public interest, use the reporting channel to report the matter immediately.
How to file a report?
The report is filed in the reporting channel of the company under suspicion at the following addresses:
- A link to Elomatic’s wp channel: https://elomatic-wb.ilmoituskanava.fi/
As an impartial service provider, the Central Chamber of Commerce manages the reporting channel in order to ensure the anonymity of the whistleblowers. Elomatic or the Central Chamber of Commerce cannot identify the source of the report, unless the whistleblower wants to disclose their contact details. No metadata related to the reports is saved in the reporting channel and the channel cannot identify the IP address of the whistleblower. With the reporting channel, the anonymous whistleblower and the persons processing the report can contact each other without risking their anonymity.
Nothing prevents the whistleblower from disclosing their contact details in the reporting channel.
Ordinary customer feedback does not belong in the reporting channel. Such feedback is given through the customer feedback channels on the companies’ websites:
Processing of reports
All reports are processed in strict confidence by persons designated to the task in accordance with the processing procedure of Elomatic
No negative consequences ensue for someone who, in good faith, tells of their suspicions and/or participates in the investigation of activity that goes against the public interest. However, the misuse of the reporting channel i.e. the intentional reporting of incorrect information can result in further actions.
The processing of the report is started by the company’s legal counsel together with the person responsible for industrial security matters. They decide on the order of the report’s further processing and determine the persons participating in the processing. The company’s CEO and the Chair of the company’s Board of Directors are always notified of a report.
In order to ensure that the report is processed appropriately, the company’s management and the necessary experts participate in the processing. Only appointed processors have access to the reports in the reporting channel. Each processor is bound by the obligation of secrecy. This ensures the confidentiality of the processing.
Leaving a report unprocessed
All reports are taken seriously. However, a report will not be processed if it is apparent that
- the report is not related to the matters to be reported in accordance with these instructions.
- the report has been filed with ill intent.
- the report does not contain enough information to enable investigating the matter.
- the issue presented in the report has already been resolved.
Additionally, reports that contain invasive information of personal nature, such as assumptions of health, political, sexual, or religious matters, do not belong in the reporting channel and shall not be processed.
Investigating a report
All reports concerning activity that goes against the public interest are investigated in accordance with the following principles:
- All reports are processed in strict confidence.
- In principle, the person whom the report concerns or who has connections to it will not participate in the processing of the report. However, a person who is the subject of the report can be heard, if necessary, in order to resolve the matter.
- If necessary, the processors use the reporting channel to anonymously ask the whistleblower further questions.
- The processor of the report or a person participating in the processing does not seek to identify the whistleblower.
The processors determine the way the report is investigated and the persons participating in the investigation on the basis of the content of the report.
Responding to a report
The company’s legal counsel gives the company’s response either through the reporting channel or directly to the whistleblower if they have left their contact details. The company’s management is informed of the reports and responses given collectively.
Report filed under the whistleblower’s name
If the report has been made under the whistleblower’s name, the name will not be made known to anyone else but the processors of the report.
In the case of a report that concerns a crime, the whistleblower is notified that their identity may be revealed in a criminal investigation performed by the authorities or in a trial.
Protection of persons identified in a report
Legislation concerning data privacy is applied to the personal data of the persons related to the report. The confidentiality of personal data is also guaranteed to ensure that the report can be investigated without disturbances.
Persons related to the report have the right to review the information in the reporting channel that concerns them and demand measures to be taken if the information is incorrect, incomplete or out of date.
Deleting the data
All data related to the person of the report is deleted once it is no longer needed for investigating the matter, responding to the report, or possible further actions.