At Softube we are guided by our company values; Healthy Ambition, Collective Exploration, and Scientific Rock n' Roller. These values are the foundation of how we conduct ourselves and how we interact with each other, our customers, suppliers, distributors and dealers, shareholders, and other stakeholders. Softube is committed to ensuring corporate compliance and promoting ethical corporate culture by observing the highest standards of fair dealing, honesty, and integrity in all our business activities internally and externally.
The policy and the procedure have been put in place to ensure any concerns raised regarding any misconduct or improper state of affairs or circumstances in relation to Softube’s business are dealt with effectively, securely, appropriately and in accordance with Swedish law Lag (2021:890) om skydd för personer som rapporterar om missförhållanden and the European Whistleblower Protection Directive. The goal is to cultivate a culture of integrity within Softube and to promote a commitment to ethical behavior and encourage a culture where wrongdoing is safely reported at an early stage. We will do this by:
Educating staff and other third parties on company standards.
Providing clear guidance on the whistleblowing process.
Explaining how to raise a concern.
Defining what type of concerns that can be raised.
Outlining any legal protection or restrictions.
Softube encourages the reporting of any instances of suspected unethical, illegal, corrupt, fraudulent, or undesirable conduct involving Softube’s business and provides protections and measures to individuals who make a disclosure in relation to such conduct without fear of victimization or reprisal. This policy will be provided to all employees of Softube upon commencement of their employment and will also be available on Bamboo HR. This policy is also available to persons outside of Softube and can be found on Softube’s website
1. Scope - what is a whistleblower and who is protected?
Who is a whistleblower? - It is someone who speaks up about suspected wrongdoing that they reasonably believe is in the public interest.
This whistleblower policy applies to any person who is, or has been, any of the following with respect to Softube:
Employee, director, member of the board, intern, job seeker with Softube, consultant, auditor, employee of a supplier or other business partner who work with Softube. Third parties who are closely connected to the person reporting a misconduct also fall under the policy – and this includes family members.
2. What is reportable conduct?
Whistleblowers are legally protected if they act in the public interest and disclose any information related to corrupt fraudulent, hazardous, or illegal activities within Softube or associated with Softube (“Reportable Conduct”). A whistleblower may make a report or disclose under this policy if you have reasonable grounds to believe that someone associated with Softube, such as an employee, director, supplier, consultant, or any other person who has business with Softube has engaged in conduct which is;
- Dishonest, fraudulent, or corrupt;
- Illegal (such as theft, dealing in or use of illicit drugs, violence or threatened violence and criminal damage to property);
- Misconduct or an improper state of aﬀairs;
- A danger, or represents a danger to the public or ﬁnancial system;
- Harassment, discrimination, victimization or bullying.
The areas of Reportable Conduct typically involve:
- Accounting fraud
- Corporate tax evasion
- Money laundering
- Financing terrorist organizations
- Environmental damage
- Breaches of product safety regulations
- Breaches of public health and safety regulations.
For the avoidance of doubt, Reportable Conduct does not include personal work-related grievances. A personal work-related grievance is a grievance about any matter in relation to a staﬀ member’s current or former employment, having implications (or tending to have implications) for that person personally and that do not have broader implications for Softube. Examples of personal work-related grievances are as follows:
- An interpersonal conﬂict between the staﬀ member and another employee;
- A decision relating to the engagement, transfer, or promotion of the staﬀ member;
- A decision relating to the terms and conditions of engagement of the staﬀ member;
- A decision to suspend or terminate the engagement of the staﬀ member, or otherwise to discipline the staﬀ member.
Personal work-related grievances should be reported to and dealt by your manager or HR Manager.
3. Making a disclosure
Softube relies on its employees maintaining a culture of honest and ethical behavior. Accordingly, if you become aware of any Reportable Conduct, it is expected that you will make a disclosure under this policy. You must be able to raise the alarm in writing, verbally or at a physical meeting. Softube’s whistleblower function is able to receive reports of misconduct and have contact with whistleblowers, follow up on what is reported, and provide feedback on the follow-up to those who raised the alarm.
There are several ways in which you may report or disclose any issue or behavior which you consider to be Reportable Conduct.
You may disclose any Reportable Conduct to the Whistleblower Protection Oﬃcers listed below:
Human Resources Manager
Chief Executive Oﬃcer
You can make a disclosure outside of business hours by contacting the above Whistleblower Protection Oﬃcers via email. You are encouraged to contact the above Whistleblower Protection Oﬃcers to obtain any additional information you may require before making a disclosure or for any clariﬁcation regarding this policy. The Whistleblower Protection Oﬃcer will safeguard your interests and will ensure the integrity of the reporting mechanism.
Softube also has a whistleblower platform available for staff members where you can report Reportable Conduct anonymously. Staff members or others can submit reports anonymously via a website and the report will be sent to the Whistleblower Protection Oﬃcers. They will get back to the whistleblower by answering to the report within the regulatory deadlines.