Whistleblowing policy

Hogia's whistle-blowing policy aims to make it easier for our employees, and the parties doing business with the company, to report suspected irregularities in the company's work. We want to inform you how to safely create and submit a whistleblower report and who to contact. The policy further describes how Hogia ensures the protection of whistleblowers, including the EU Directive (2019/1937) on the protection of whistleblowers (EU Whistleblower Directive). Finally, the policy also describes your legal rights and how to exercise them if necessary.

Who can blow the whistle?

A whistleblower can be an employee or a person with self-employed status, a shareholder, a member of the company's administrative management or supervisory board, or a volunteer. A whistleblower can also be any person who works under the supervision and direction of the contractors, the subcontractors, and the suppliers to Hogia.

Note that you can still be a whistleblower even if the work-based relationship has ended, as well as if it has not yet started.

It is always possible to file a whistleblowing report anonymously. This does not affect your rights and protection under the Whistleblower Act. However, complete anonymity may make it more difficult for Hogia to investigate the problem or take the actions we would like to take.

Who is responsible for the whistleblower report?

Hogia is responsible for handling the whistleblower report. Thus, Hogia has a responsibility to protect the whistleblower, which includes not revealing the identity to anyone, unless you expressly agree to this or there is an obligation to disclose the identity by law. The recipient of the whistleblower report is the supplier of the whistleblower system, Interaktiv Säkerhet, and the case managers at Hogia. The case managers have an obligation to investigate the whistleblower case within the specified time period, impartially and objectively, and to ensure that the whistleblowing does not lead to consequences for the whistleblower. The case managers are the HR manager, the Security Manager, and the Corporate Counsel. If a case manager is judged to be bias or have a conflict of interest, he or she is excluded from the case.

What can be reported in a whistleblowing report?

In order to file a whistleblower report, reasonable grounds to believe that there are false or actual violations of applicable rules or regulations in relation to Hogia are expected.

Only information and personal data relevant to the handling of the whistleblower report should be reported. Personal work-related complaints, such as conflicts between you and other employees or a decision concerning your employment or engagement, should not be reported in a whistleblower report. This should instead be taken up with the responsible manager, the company manager, or the HR Business Partner.

The Whistleblower Act specifically states the importance of reporting in the following areas:

  • Public procurement
  • Financial services, products and markets and prevention of money laundering and terrorist financing
  • Product safety and compliance
  • Transport safety
  • Environmental protection
  • Radiation protection and nuclear safety
  • Food and feed safety, animal health and welfare
  • People's health
  • Consumer protection
  • Protection of privacy and personal data


Where can you file a whistleblower report?

It is possible to file a whistleblower report in writing or verbally, or both.

Reporting in writing is possible via the external whistleblower system, Whistlelink, managed by Interaktiv Säkerhet, via link Whistleblowing report start | Whistle link

Verbal reporting is possible via telephone calls to Interaktiv Säkerhet (more information can be found in the Whistlelink system), or through a meeting with either Interaktiv Säkerhet or with Hogia's case managers.

Receipt of the whistleblower report is confirmed to you as the whistleblower within seven days of reporting.

Communication about whistleblowing is handled via the system, where Hogia may, if necessary, ask for additional information about the report. You will receive feedback via the Whistlelink system no later than three months from the confirmation that the report has been received.

If internal reporting as per above is not appropriate, it is possible to file a whistleblower report externally to competent authorities and, in relevant cases, to institutions, bodies, offices or agencies for the EU via external reporting, see more in the list below.

Personal data

Our goal is to always protect the personal data we process. This means that we are always committed to protecting your privacy and complying with applicable personal data legislation, including but not limited to the General Data Protection Regulation (GDPR).

When you file a whistleblower report, we will process the personal data in it to fulfill our legal obligations under, among other things, the Whistleblower Act. Please find more information about how personal data in a whistleblower report is treated in Interaktiv Säkerhets’s privacy policy here: https://www.whistlelink.com/privacy-notice/

What are your rights?

Hogia is responsible for implementing and maintaining necessary and reasonable measures to prohibit any form of retaliation against you for filing a whistleblower report, including threats and attempted retaliation.

As a further example, prohibitions against retaliation due to the submission of a whistleblower report include, for example, prohibitions against:

  • Suspension, layoff, dismissal, or equivalent measures
  • Demotion or non-promotion
  • Transfer of duties, change of workplace, reduction of salary, change of working hours
  • Interruption of education
  • A negative performance appraisal or employment reference
  • Imposing or administering disciplinary action, reprimand, or other penalty, including a financial penalty
  • Coercion, threats, harassment, or ostracism
  • Discrimination, unfavorable or unfair treatment
  • Failure to convert a temporary employment contract into permanent employment, where you had a legitimate expectation that you would be offered permanent employment
  • Failure to renew or prematurely terminate a temporary employment contract
  • Damage, including to your reputation, especially in social media, or financial loss, including loss of business and loss of income
  • Blacklisting on the basis of a sector or industry-wide informal or formal agreement, which may mean that you will not be employed in such sector or industry in the future
  • Early termination or cancellation of a contract for goods or services
  • Suspension of a license or permit
  • Psychiatric or medical referrals

External reporting - How do I register a report externally to the competent authority?

In addition to the information in the Whistleblower Policy, competent Authorities provide comprehensive and independent information and advice on the procedures and remedies available, as well as protection against reprisals and your rights. You can also make a report to the competent authority responsible for the area to which your report relates. In connection with the entry of the new whistleblower law, the authorities below have set up external whistleblower channels where you can turn to with your suspicions. More information is available on the respective authority's website.

These authorities are: The Swedish Work Environment Agency, the Swedish Housing Agency, the Swedish Electrical Safety and Security Agency, the Ecocrime Agency, the Real Estate Agency Inspectorate, the Financial Supervisory Authority, the Public Health Agency, the Maritime and Water Authority, the Privacy Protection Agency, the Inspectorate for Strategic Products, the Inspectorate for Health and Care, the Chemicals Inspectorate, the Consumer Agency, the Competition Authority, the Food and Drug Administration, the Medicines Agency, the County Administrative Boards, the Authority for public safety and preparedness, the Environmental Protection Agency, the Post and Telecommunications Agency, the Government Office, the Auditors' Inspection, the Tax Agency, the Swedish Forestry Agency, the Swedish Gaming Inspectorate, the Governmental Energy Agency, the Governmental Agricultural Agency, the Board for Accreditation and Technical Control, the Radiation Safety Authority and the Swedish Transport Agency.