Whistleblower Policy

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
Bribery
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.

Internal Reporting
You may disclose any Reportable Conduct to the Whistleblower Protection Oﬃcers listed below:

Human Resources Manager
Lorna McGeown
lorna@softube.com

Chief Executive Oﬃcer
Oscar Öberg
oscar@softube.com

General Counsel
Åsa Enström
asa@softube.com

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.

Here you can find the platform link

Whistleblower Platform

4. Investigation

Softube will investigate all matters reported under this policy as soon as practicable after the matter has been reported. The Whistleblower Protection Oﬃcer will investigate the matter and where necessary, appoint an external investigator to assist in conducting the investigation. All investigations will be conducted in a fair, independent, within regulatory timelines and all reasonable eﬀorts will be made to preserve conﬁdentiality during the investigation.
If the report is not anonymous, the Whistleblower Protection Oﬃcer or external investigator will contact you, by your preferred method of communication to discuss the investigation process and any other matters that are relevant to the investigation.
Where you have chosen to remain anonymous, your identity will not be disclosed to the investigator or to any other person and Softube will conduct the investigation based on the information provided to it.
The Whistleblower Protection Oﬃcer will provide you with feedback on the progress and expected timeframes of the investigation. The person against whom any allegations have been made will also be informed of the concerns and will be provided with an opportunity to respond (unless there are any restrictions or other reasonable bases for not doing so).
To the extent permitted by law, the Whistleblower Protection Oﬃcer may inform you and/or a person against whom allegations have been made of the ﬁndings. Softube will document the ﬁndings in a report however any report will remain the property of Softube and will only be shared with you or any person against whom the allegations have been made if Softube deems it appropriate.

5. Protection of whistleblowers

Softube is committed to ensuring that any person who makes a disclosure is treated fairly and does not suﬀer detriment and that conﬁdentiality is preserved in respect of all matters raised under this policy.

Protection from legal action
You will not be subject to any civil, criminal or administrative legal action (including disciplinary action) for making a disclosure under this policy or participating in any investigation. Any information you provide will not be admissible in any criminal or civil proceedings other than for proceedings in respect of the falsity of the information.

Protection against Detrimental Conduct
Softube (or any person engaged by Softube) will not engage in “Detrimental Conduct” against you if you have made a disclosure under this policy.

Detrimental Conduct includes actual or threatened conduct such as the following (without limitation):

Termination of employment
Injury to employment including demotion, disciplinary action;
Alternation of position or duties;
Discrimination;
Harassment, bullying or intimidation;
Victimization
Harm or injury including psychological harm;
Damage to a person’s property;
Damage to a person’s reputation;
Damage to a person’s business or ﬁnancial position;
or Any other damage to a person.

Softube also strictly prohibits all forms of Detrimental Conduct against any person who is involved in an investigation of a matter disclosed under the policy in response to their involvement in that investigation.

Softube will take all reasonable steps to protect you from Detrimental Conduct and will take necessary action where such conduct is identiﬁed. If you are subjected to Detrimental Conduct as a result of making a disclosure under this policy or participating in an investigation, you should inform a Whistleblower Protection Oﬃcer or eligible Government Agency in accordance with the reporting guidelines outlined above.

You may also seek remedies including compensation, civil penalties, or reinstatement if you suﬀer loss, damage or injury because of a disclosure and Softube failed to take reasonable precautions and exercise due diligence to prevent any Detrimental Conduct.

Protection of Confidentiality
All information received from you will be treated conﬁdentially and sensitively. You will not be required to provide your name when making a disclosure. If you report on an anonymous basis, you will of course qualify for the protections in this policy.

A reporting person may not be held liable for breach of confidentiality, provided that the reporting person had reasonable cause to believe that the reporting of the information was necessary to disclose the reported misconduct.

Where it is necessary to disclose information for the eﬀective investigation of the matter, and this is likely to lead to your identiﬁcation, all reasonable steps will be taken to reduce the risk that you will be identiﬁed. For example, all personal information or reference to you witnessing an event will be redacted from any report, you will be referred to in a gender-neutral context, where possible you will be contacted to help identify certain aspects of your disclosure that could inadvertently identify you. Any disclosure under this policy will also be handled and investigated by qualiﬁed staﬀ.
Softube will also take the following measures for protecting your identity:

All paper and electronic documents and other materials relating to disclosures will be stored securely;
If you submit via the website, access to all information relating to a disclosure will be limited to those directly involved in managing and investigating the disclosure;
If you submit via the website, only a restricted number of people who are directly involved in handling and investigating a disclosure will be made aware of your identity (subject to your consent) or information that is likely to lead to your identiﬁcation;
If you submit via the website, communications and documents relating to the investigation of a disclosure will not be sent to an email address that can be accessed by other staﬀ; and
Each person who is involved in handling and investigating a disclosure will be reminded about the conﬁdentiality requirements.
If you are concerned that your identity has been disclosed in relation to a disclosure, and without your consent, you should inform a Whistleblower Protections Oﬃcer or eligible Government Agency immediately.

External Reporting

Where you do not feel comfortable making an internal report, or where you have made an internal report, but no action has been taken within a reasonable time, you may report externally.
An external reporting channel enables staff to report a Reportable Conduct to a government agency designated by the government. The external reporting channel must receive, follow up and provide feedback on reports of misconduct in certain specific areas. You will be covered by the protections outlined in this policy if you have reported your concerns to a government agency.

You can blow the whistle directly to an external reporting channel without first reporting it internally. The whistleblower can choose whether he or she wants to report internally or externally.

You must first have reported externally without reasonable measures being taken before raising the alarm publicly, for example via the media. There are exceptions to that rule, for example if there is an imminent or obvious danger to life, health, safety or risk of extensive damage to the environment. Or if there is reasonable reason to assume that an external report would lead to a risk of reprisals or that the misconduct would likely not be remedied effectively.

However, it should be emphasized that constitutional protection does not change due to the new law. For example, there is already today constitutional protection when someone publishes or communicates information for publication in a constitutionally protected medium.

Anonymity

When making a disclosure, you may do so anonymously. It may be diﬃcult for Softube to properly investigate the matters disclosed if a report is submitted anonymously and therefore Softube encourages you to share your identity when making a disclosure, however you are not required to do so. Where a disclosure has been made externally and you provide your contact details, those contact details will only be provided to a Whistleblower Protection Oﬃcer with your consent.

Internal Reporting
You may disclose any Reportable Conduct to the Whistleblower Protection Oﬃcers listed below: