Laerdal Medical whistleblower procedure
Laerdal Medical whistleblower procedure
Laerdal Medical believes that openness and good communication throughout the organization promote a better work culture. Laerdal Medical has therefore established a whistleblower channel to enable employees and external parties to report concerns about possible illegal actions and breaches of Laerdal Medical's Code of Conduct.
What can be reported?
Laerdal Medical encourages everyone to report issues of concern that may threaten the company's finances, operations, or reputation. This includes fraud, corruption, harassment, discrimination, violations of health and safety standards, environmental and human rights laws, and other breaches of the Code of Conduct.
It is the whistleblower’s prerogative to choose what information is provided. However, to ensure sufficient information and allow Laerdal Medical to perform adequate follow-up actions, the reports should include as many details as possible and, if available, supporting evidence.
How to report a concern
We strongly prefer direct communication of the issue to an internal employee - a supervisor in the same department or management. In cases where this is difficult, you may use Laerdal Medical's independent whistleblower channel managed by PricewaterhouseCoopers (PwC). PwC is committed to a high ethical standard and will handle all notifications confidentially.
You have three ways of using the whistleblower channel:
- Fill out a private and secure online form
- Send an e-mail to firstname.lastname@example.org
- Send a letter via post to: Advokatfirmaet PricewaterhouseCoopers,
Attn. Marianne S. Pilgaard, Postboks 748 Sentrum, N-0106 Oslo, Norway
By reporting through the whistleblower channel managed by PwC, the receiver will be able to give feedback through the system.
A proper investigation may prove difficult if the information provided cannot be tested or verified and the investigator is unable to obtain further information from the whistleblower.
How concerns are handled
The following are to be observed in the management of all whistleblower reports:
- All reports are to be taken seriously
- All reports will be sufficiently investigated within a reasonable timeframe and in a fair, open-minded, and objective manner
- Confidentiality and information security
- Protection of whistleblowers
- Whistle-blowers reporting in good faith will not be subject to reprisals
- Non-anonymous whistleblowers will get timely feedback and information about the process
- Any person accused of a breach of the Code has the right to be informed of the nature and cause of the accusation against them and to be heard (contradiction)
- The process is to be documented in writing (notoriety)
Below is a summary of the main steps in handling whistleblower reports.
PwC will perform a preliminary evaluation and quality assurance of all notifications received through the whistleblower channel before delivering an initial report to People and Sustainability/CHRO at Laerdal Medical. If the report reveals conditions that require investigation, an investigation team will be appointed.
External advisors or internal resources may be used to conduct the investigation. The decision on who will conduct the investigation will be based upon the nature of the violation reported and the resources available.
The whistleblower, unless anonymous, and the person(s) alleged to have breached the Code shall receive information on the progress of the report. They will be notified, as a minimum, when the case is considered and concluded, including instances where no irregularities or issues of non-compliance are found in the investigation. Whistleblowers that are not parties to the case are in principle not entitled to any information about the execution of the investigation or the conclusion in the summary report, and the information provided will be decided on a case-to-case basis.
A summary report with the final results of the investigation will be completed within a reasonable time and will be reviewed by People and Sustainability/CHRO and/or external advisor as appropriate. The summary report shall be filed according to the internal archive routine and data protection acts.
Based on the outcome of the investigation, the CEO and/or chair of the board of Laerdal Medical ASA shall take appropriate action and may impose necessary or fitting sanctions, including any preventive measures, disciplinary sanctions, or termination of a supplier contract, etc. For employees, consequences may involve verbal or written warnings or, in the case of a grave offense, termination of or summary dismissal from their employment.
Protection of whistleblowers and of the subjects of whistleblower reports
As it is important for Laerdal Medical to provide a mechanism to safely report illegal activities and serious misconduct, it is equally important for the company to protect and to avoid damage to the reputation of innocent employees or board members who are the subject of a reported violation.
For these reasons, Laerdal Medical will conduct its investigations of any reported violation as discreetly as possible, and in a confidential manner to the greatest extent possible commensurate with carrying out a thorough and adequate investigation. Furthermore, to the extent possible, all reasonable efforts will be made to treat the whistleblower's identity confidential, unless permission in writing (including email) has been obtained from the whistleblower. The protection of identity shall also be taken into consideration during the initial evaluation and the subsequent risk assessment when scoping the investigation, hereunder the existing level of risk exposure without disclosing the name of the whistleblower. All investigations will be conducted in a confidential manner, so that information will be disclosed only as needed to facilitate review of the investigation or otherwise as required by law.
Laerdal Medical prohibits any retaliation against whistleblowers and will provide adequate measures to prevent retaliation within the organization. Retaliation is in itself a breach of the company’s policy, and any such acts may lead to appropriate sanctions as described above. Retaliation is any negative action, practice, or neglect as a consequence of or reaction to the whistleblower’s report, e.g., victimization, threats, harassment, discrimination, social exclusion, warnings, deprivation of work tasks, groundless relocation, degradation, poor wage development, suspension, dismissal, summary dismissal or disciplinary punishment.
Any whistleblower who experiences retaliation must report it.
Protection of sources
The identity of the person reporting shall not be disclosed without permission in writing from the notifying party.
All investigations will be conducted in a confidential manner, so that information will be disclosed only as needed to facilitate review of the investigation or otherwise as required by law.
Reporters who bring attention to a breach of the Code in good faith will not face any risk of retaliation or other unfavorable treatment, even if it is later discovered that they were mistaken. However, appropriate disciplinary or legal action will be taken against any person who is found to have made a disclosure maliciously that they know to be untrue, or without reasonable grounds for believing that the information supplied was accurate.
Handling of reports of concerns will be done in accordance with the Norwegian Personal Data Act and Regulations on the Processing of Personal Data.