Whistleblowing: What is it?
Our whistleblowing channel allows individuals to confidentially report suspicions of misconduct, illegal activity, or ethical violations.
Why is it important?
The Whistleblowing Channel serves as a vital tool for upholding ethical standards and fostering trust within our organization.
We expect all employees to adhere to our ethical guidelines and comply with relevant laws in their daily work. If any staff member or associated individual suspects wrongdoing, they can safely report it via the whistleblowing channel.
What can be reported?
The Whistleblowing Channel serves as a vital tool for upholding ethical standards and fostering trust within our organization.
Our Whistleblowing Channel can be used by employees and anyone connected to our organization to anonymously report issues such as:
- Bribery, corruption, or money laundering
- Tax evasion or involvement in the gray economy
- Illegal business practices or unfair competition
- Violations of environmental or occupational safety regulations
- Breaches of data protection laws
- Non-compliance with laws
- Disruptions to workers’ rights to organize
- Unilateral alterations to job duties
- Any other violations of laws or ethical standards
Reports should be submitted in good faith, and knowingly false reports are prohibited and may result in legal consequences.
Who can use the channel?
This whistleblowing system is available to all stakeholders connected to our organization.
How to report?
Reports can be submitted anonymously through the channel.
Only specific individuals within Appmore Ltd. — the CEO, COO, and Chief People and Workplace Safety Representative have access to the reports. All notifications will be kept confidential.
Privacy policy for handling reports of wrongdoing (whistleblowing channel)
1. Controller
Appmore Ltd
Address: Keilaranta 02150 Espoo Finland
Contact person: Kai Lempinen (CEO)
2. Purpose and Legal Basis of Processing
The Whistleblowing Channel is established to provide all employees of Appmore, as well as external stakeholders, a confidential means to report suspected cases of wrongdoing. Personal data must be processed to investigate these reports and to determine and implement any necessary actions.
Appmore is committed to protecting the privacy of individuals and will only use personal data collected through the Whistleblowing Channel in accordance with data protection laws and good practices. Misuse of the Whistleblowing Channel is prohibited and may result in legal action.
Legal Basis:
- The processing of whistleblowers’ personal data is based on their consent (GDPR, Art 6.1(a) and Art 9.2(a)).
- The processing of personal data regarding the subjects of whistleblowing reports and those handling the reports is based on Appmore’s legitimate interest (GDPR, Art 6.1(f)). This is in line with Directive (EU) 2019/1937, which governs the protection of individuals reporting breaches of Union law.
- The processing of special categories of personal data is necessary to fulfill legal obligations in the field of employment law (GDPR, Article 9.2(b)).
3. Data Sources
Whistleblowers may include employees of Appmore or external stakeholders. Information relevant to investigating wrongdoing may also be collected from other individuals or organizations involved in the case.
4. Categories of Data Subjects and Data
Whistleblowers: Reports may be submitted anonymously, though some whistleblowers choose to include personal information (such as name, location, financial data, or multimedia).
Subjects of Reports: Reports of wrongdoing may contain personal details about the subjects (such as name, location, financial data, or multimedia), behavior, and other circumstances, including sensitive personal data such as health information.
Processors: Personal data collected from individuals handling whistleblowing reports include name, title, usernames, and log data.
5. Access to and Disclosure of Personal Data
Only employees assigned by Appmore to investigate reports of wrongdoing have access to the data. The whistleblowing channel is managed by Appmore. We ensure data is handled in accordance with relevant data protection laws.
Personal data may be disclosed to authorities or third parties, such as external auditors, in accordance with the law.
6. Data Storage Periods
As a general rule, data is stored for no longer than two (2) years after the investigation concludes. However, longer retention may be required due to legal obligations, such as criminal or occupational safety regulations.
8. Rights of Data Subjects
Data subjects have the right to:
- Request confirmation of whether their data is being processed and access to that data.
- Request the rectification of their personal data.
- Request restriction of the processing of their data under certain conditions (GDPR, Art 18).
- Lodge a report with the Data Protection Officer.
Additionally, they can:
- Request the erasure of their personal data.
- Withdraw their consent at any time if the processing is based on consent.
- Object to the processing of their personal data if it is based on legitimate interest (GDPR, Art 21).
Data subjects can request access to their data or exercise their other rights by contacting [email protected]. Verification of identity is required for data access requests.
9. Enquiries Concerning the Processing of Personal Data
For questions regarding personal data processing, please contact [email protected].
Report an observation
Through this whistleblowing channel, individuals can confidentially report any suspicions of illegal activity, policy violations, or other forms of misconduct. We recommend enabling incognito mode when using a shared computer. Required fields are marked *