Tell me - Report infringements

What is Tell Me?

Tell Me is NCC’s whistleblowing channel where you as an employee (the channel is also open for consultants, suppliers, customers or other business partners) can report possible violations of the law, NCC Code of Conduct, Supplier Code of Conduct or policies and directives.

What is whistleblowing?

Whistleblowing means that an individual informs the company about a concern or suspected wrongdoing. This is to protect the company, employees and other internal and external stakeholders.

What type of incidents should I report?

Incidents that you think violate the NCC Code of Conduct, Supplier Code of Conduct and other policies and directives. It may also be a violation of a law, rule, regulation and/or a direct threat to public interest. Antitrust violations and corruption are examples of issues that should be reported.

What should I do if it is just a suspicion, and I am uncertain whether anything has happened?

If you are unsure about a specific course of action, you should ask your manager, HR, Legal, Compliance or Finance if you want to know if something is right or wrong. We would rather you ask us about a situation that turns out to be harmless than let potential unethical behavior go unchecked because you were unsure. Read more at the Ask Me pages.

For which countries can a report be filed?

Reports can be filed for incidents that have taken place in all our locations, joint ventures, and subsidiaries. The Tell Me line can be accessed in all local languages.

What is retaliation?

Retaliation means that a whistleblower or an individual who has participated in an investigation as, for instance, a witness is punished in one way or another. The punishment might be demotion or that the employment contract is terminated. NCC has a whistleblower protection policy that strictly forbids any retaliation against any person who reports a concern in good faith. The policy states that retaliation is an action subject to disciplinary procedures.

What if I face retaliation?

Complaints made in good faith will not expose you to any sanctions, regardless of whether or not the underlying facts prove to be correct or result in any corrective action. If you believe you have faced retaliation of any kind, please report it so it can be investigated.

What will happen to those accused?

It depends if the allegation is substantiated or not. If the breach is substantiated, NCC will take appropriate action. This may include disciplinary action, up to and including termination and possibly legal action, subject to applicable laws and depending on the circumstances. NCC may also take other actions to prevent recurrence such as training.

Why should I report what I know?

A strong, transparent, and positive culture of integrity is central to NCC and in line with the Star Behaviors and Core Values – Honesty, Respect and Trust. Acting with care is the Star Behavior which informs how we are expected to take responsibility for our actions and use of resources, but also to mitigate risk and act with integrity to ensure safe, high-quality, and sustainable operations.

We all have a responsibility for acting in an ethically correct manner and letting the appropriate people know if someone is not acting in an ethically correct manner or acting in breach of any law or regulation.

I am aware of some individuals involved with unethical conduct, but the conduct doesn't concern me. Why should I report it?

We encourage you to come forward and raise concerns to prevent any kind of wrongdoing. All unethical conduct, at any level, ultimately hurts the company and all employees, including you. If you know of any incidents of misconduct or ethical breaches, consider it your duty to yourself and your co-workers to report it.

Does management really want me to report?

They certainly do. NCC does not tolerate non-compliant behavior and will exercise consequential management in the event of breaches of the NCC Code of Conduct. The sooner we know, the earlier we can act and hopefully minimize the negative impact of misconduct.

Isn’t this system just an example of someone watching over me?

NCC is committed to its Core Values – Honesty, Respect and Trust. In line with this commitment, we encourage and expect employees and others who have serious concerns about any aspect of NCC’s work to come forward. The objective of Tell Me and any investigation conducted by NCC is to find out the facts of what has happened, irrespective of where and at what level in the organization.

Who can report on the Tell Me line?

Anyone can file a report on the Tell Me line. Most reports are filed by employees, but reports can also be filed by consultants, suppliers, customers, or other business partners.

Who receives the reports?

The reports made via the Tell Me whistleblowing channel are received by Group Compliance, where each report is assessed. The whistleblowing line is provided by an external company called People InTouch, and is available 24 hours a day, 7 days per week in any language, by telephone or web submission.

Who investigates the reports?

Depending on what the report is about and where the conduct took place different parts of the organization are responsible for the investigation. Reports concerning harassment, discrimination, or fair employment, may typically be assessed by HR, while other categories of reports may be assessed by Legal or another Group Function like Security. Those conducting investigations in NCC are independent in the handling and investigation of whistleblower reports.

Who is protected by NCC’s whistleblower policy?

Persons protected include those with a range of profiles who could acquire information on breaches in a work-related context. This could include employees, unpaid trainees, shareholders with active assignments, and members of supervisory bodies (including the Board of Directors), independent third-party contractors, subcontractors, and suppliers. The whistleblower protection also applies to those assisting whistleblowers, such as colleagues and relatives.

If I have a concern, how should I report it?

Ideally, we encourage you to report any suspected Code of Conduct violations directly to your manager, your manager’s superior, Human Resources, Legal, Finance or your Group Compliance. You may do this by mail, telephone or in person. However, if you feel you cannot report to any of these resources, you can use Tell Me, the whistleblower channel where reports can be made anonymously.

Where do these reports go? Who can access them?

Reports are entered directly into the whistleblowing service provider’s secure server, which is hosted outside NCC’s IT environment. Our service provider, People InTouch, with their Speak Up system, makes these reports available only to authorized individuals within NCC who are responsible for assessing the reports and conducting the investigations. Each of these recipients is committed to keeping the reports confidential.

What if those accused get access to my report?

The Tell Me whistleblowing process and our investigation process are designed so implicated parties are not notified about the report or granted access to reports in which they have been named.

I am concerned the information I provide will ultimately reveal my identity. How can you assure me that will not happen?

It is never possible to trace back the reporter’s identity – any identifiable information such as an IP address and voice message is never provided to NCC by the external provider. The system will provide the reporter with a unique case number. This case number enables the reporter to listen to or read the response from NCC when they return to the system.

Your identity will always be kept confidential. You can also choose to be anonymous, where permitted by local laws. To further ensure your anonymity, you may consider not revealing any identifying details as part of your report. However, if you choose to be anonymous, remember to go back to your filed report since Group Compliance might have sent questions to you. It might be more difficult to conduct a proper investigation where the reporter is anonymous so consider this seriously before submitting your report.

What should my report contain?

It is important for the investigation that the reporter gives as much information as possible to assist in the investigation (always helpful: “what, when, how, where” – “who” when necessary for solving the matter). Moreover, any documentation that can be provided will be helpful.

If you remember something important about the issue after filing the report, you can use your password to return to the Tell Me Line and access your original report. At that point, you can add more details or answer questions you may have received from Group Compliance.

Will I get any feedback regarding the result of my filed report?

If the reporting channel chosen by the reporter is the external whistleblowing line, Group Compliance provides the reporter with a confirmation receipt within about 48 hours. Sometimes this confirmation will contain questions that would be helpful for the investigation.  The reporter will also be notified upon closure of the investigation. Depending on the sensitivity of the investigation, certain non-confidential information might be shared with the reporter, however, this never includes information containing personal details.

How long is the data kept?

Any data provided when leaving a message via the Tell Me phone or web system will be processed for the purpose of following up and investigating the reported message, in adherence with local legal obligations. The information will be stored as long as it is necessary for the purpose of handling the case but no longer than 2 years.

The processing of personal data through the whistleblowing system is strictly regulated under the General Data Protection Regulation (GDPR).

Who will get access to the data?

All reports are received by Group Compliance and are processed under a strict need to know policy. The person who needs to investigate the case will be granted access and will usually be a member of NCC’s Legal, Compliance or HR departments depending on what the case concerns and where in the business a violation may have taken place. Depending on the type of violation, other departments may also be involved (e.g., Internal Audit) and sometimes we need to bring in external expertise to help us in the investigation.

Are there other ways to report?

Outside of the internal resources listed above, the most secure handling is provided by the external Tell Me line. However, you can also email the Head of Compliance (link email) or send a letter to: Head of Compliance, Group Legal & Risk, 170 80 Solna, Sweden.

You can also contact a local resource covering the legal entities in each country or as an alternative report to local authorities

• Contact person - Sweden
• Contact person - Denmark
• Contact person - Finland
• For Norway, Please contact Compliance@ncc.se

Local authorities in Sweden, Denmark and Finland

• Sweden
• Denmark
• Finland