Whistleblowing

Why should I report a concern about an actual or potential violation of law or Code of Conduct in NCC's operations? 

A strong, open, and positive integrity culture is central to NCC and in line with our Star behaviors and values – Honesty, Respect, and Trust. Acting with care is a Star behavior that describes how we are expected to take responsibility for our actions and use of resources, and to mitigate risks and act with integrity to ensure a safe, high-quality, and responsible operation.

We all have a responsibility to act with a high ethical standard and to inform relevant persons if someone is not acting in accordance with the NCC Code of Conduct. If you become aware of a breach of the NCC Code of Conduct, we want you to speak up. Oftentimes, early reporting can help resolve an issue quickly and minimize harm.

Who can report a concern about an actual or potential violation of law or NCC's Code of Conduct related to NCC's operations?

Anyone can submit a report. Most reports are submitted by our employees, but we also receive reports from consultants, suppliers, customers, or other business partners.

If I know about a potential breach of NCC’s code of Conduct. How can I raise it?

To report a concern about a breach, you can:

• Talk to your manager, or your manager’s manager.
• Talk to a relevant functional team, like HR, Finance, Legal or Security.
• Contact Head of Compliance via an email to Compliance@ncc.seor a send letter to: Head of Compliance, Group Legal & Risk, 170 80 Solna.
• Access the NCC whistleblowing hotline, Speak Up: ncc.com “Sustainability” or on MyNCC. When reporting through SpeakUp you have the option to make the report anonymously. Our SpeakUp hotline is externally hosted and available 24/7. You can report in English or in any language of the countries where we have operations.

For additional information and guidance, NCC employees can refer to the Group Compliance Directive and information on the MyNCC intranet.

What should the report contain?

It is important for the investigation that the person reporting provides as much information as possible that can be helpful in the investigation (always “what, when, how, where” – “who” when necessary to resolve the case). Additionally, any documentation that can be provided is helpful. If you come up with something else important after you have submitted the report, you can use the password you receive when reporting to access your original report and add more information or answer questions that you may have received from Group Compliance.

Are there other ways to report?

In addition to the internal resources mentioned above and the whistleblowing hotline SpeakUp, there are also locally appointed contact persons in each EU country.

• Kontaktperson - Sverige
• Kontaktperson - Danmark
• Kontaktperson - Finland

How can you ensure anonymity?

NCC is unable to trace the identity of the person submitting a report in the whistleblowing hotline SpeakUp. No identifiable information such as IP address and voice message is disclosed to NCC by the external supplier. The person submitting the report receives a unique case number from the system. Using the case number, the person who submitted the report can listen to or read the response from NCC when they log back into the system.

If known, your identity is always kept confidential. To further ensure your anonymity, you may consider not disclosing any identifiable information when submitting the report. If you choose to remain anonymous, remember to return to your submitted report in the system as Group Compliance may have sent questions to you. It can be more difficult to conduct a thorough investigation if the person reporting is anonymous, so think carefully before submitting your report.

Who receives the reports submitted to the whistleblowing hotline?

The whistleblowing hotline, SpeakUp, is provided by an external company. Reports made in SpeakUp are directly entered into the whistleblowing service's secure server located outside NCC's IT environment. Our supplier makes the reports available only to persons within NCC who are designated to evaluate the reports and conduct investigations. Each of these recipients has committed to keeping the reports confidential.

Who investigates the reports?

All reports submitted in SpeakUp are reviewed by Head of Compliance and handled according to a strict confidentiality policy. Depending on what the report is about and where the suspected violation occurred, different parts of the organization are responsible for the investigation. Reports of harassment, discrimination, or employment conditions can normally be investigated by HR, while other reports may need to be assessed by Legal or another corporate function such as Group Purchasing and Group Security. Depending on the type of violation, other departments may also be involved (such as Internal Audit), and in some cases, we may need to bring in external expertise to assist with the investigation. The resources that handle and investigate whistleblower reports at NCC are independent functions.

What happens to those accused?

It depends on whether the accusation is substantiated or not. If the breach is confirmed, NCC will take appropriate action. This may involve disciplinary measures, which depending on circumstances and applicable laws, can even lead to termination and legal consequences. NCC may also take other measures to prevent the violation from recurring, such as training.

What does it mean that NCC has a whistleblower protection policy?

NCC has a whistleblower protection policy that strictly prohibits retaliation against persons who in good faith report a violation of the Code of Conduct or law. Retaliation means that a whistleblower or a person who has participated in an investigation, such as a witness, is punished for this participation.

What happens if I, as a whistleblower, suffer retaliation?

If you believe you have been subjected to any form of retaliation, you should report it so that an investigation can be conducted.

Will I receive any feedback on the outcome of my submitted report?

If the person reporting chose the whistleblowing hotline as the reporting channel, the person receives a confirmation from Group Compliance within approximately 48 hours (Business Days). Be aware that the confirmation may also contain questions that can be helpful during the investigation. When the investigation is completed, the informant receives a message about it in SpeakUp. Depending on how sensitive the investigation is, some non-confidential information may be shared with the informant, but never information containing personal data.

How long are the data stored?

All data submitted in your report via the SpeakUp phone or web system is processed with the aim of following up and investigating the reported message, in accordance with local legal obligations. The information is stored as long as necessary to process the case. The processing of personal data via the whistleblowing hotline is strictly regulated according to the General Data Protection Regulation (GDPR).