Whistleblower channel

TechTribe’s whistleblower channel for reporting misconduct

TechTribe strives to maintain a good business culture and discourage corruption and other irregularities. So-called whistleblowers play a central role in protecting and promoting important values in a democratic society, such as openness and transparency. The TechTribea Whistleblower Channel is part of our efforts to prevent and detect wrongdoing and to protect whistleblowers who report wrongdoing. Via TechTribe’s whistleblower channel, whistleblowers can report wrongdoing and irregularities within TechTribe, without having to worry about negative consequences.

What can be reported?

Whistleblowing must relate to misconduct that there is a public interest in their coming to light. The information must therefore concern the public and not the reporting person’s own working or employment conditions. Relationships concerning an individual may in some cases be of public interest if, for example, it concerns repeated or systematic violations that can be considered unacceptable from a broader societal perspective. Violations of internal regulations such as codes of conduct may in some cases be of public interest.

Whistleblowing may also refer to violations of certain EU rules and Swedish rules that implement or supplement EU rules. The EU rules covered are listed in Annex 1 to Directive (EU) 2019/1936 of the European Parliament and of the Council of 23 October 2019 on the protection of persons reporting breaches of Union law, which is available here.

The reporting person does not need to have actual evidence, but reasonable apprehension or suspicion is sufficient.

What should not be reported?

The reporting channels shall not be used for:

General expressions of dissatisfaction. Such matters must be communicated to the immediate manager.
Reporting of security classified information under the Security Protection Act (2018:585) or other information related to national security.

Who can report and get protection

The people protected by the Whistleblower Act are people with a so-called work-related connection to the business. It is a question of employees or other persons who in one way or another are active in or in connection with the business where the misconduct occurs. It also includes part-time employees, job seekers and people who have ended their employment. The reporting person indicates belonging to the circle of persons in connection with reporting.

What the protection means

The protection prohibits TechTribe from a) preventing or attempting to prevent reporting and, as a result of reporting, taking b) retaliation. The protection also consists in c) freedom from liability and the right to damages in case of violation of the prohibitions.

Obstructive measures can consist of the operator offering a benefit for someone not to consult with their employee organisation.
Retaliation is, for example, dismissal, non-promotion, changed duties, changed workplace, salary reduction and changed working hours.
Protection in the form of freedom from liability means that whoever, by blowing the whistle according to the law, violates a duty of confidentiality cannot be held liable for having violated the duty of confidentiality.

For protection in the form of freedom from liability, it is required that the reporting person had reasonable grounds to assume that the reporting of the particular information covered by the duty of confidentiality was necessary to reveal the misconduct.

Exemption from liability is not granted in the event of a willful breach of the duty of confidentiality which, according to the Publicity and Secrecy Act (OSL), restricts the right to communicate and publish information in accordance with the Freedom of the Press Ordinance or the Freedom of Expression Act, so-called qualified confidentiality, or breach of confidentiality according to the Act (1971:1078) on defense inventions.

Exemption from liability is also not granted when a reporting person gives out documents. Exemption from liability, on the other hand, applies if the reporting person verbally or otherwise reports information from a document without disclosing the document.

If the reporting person commits a crime through the collection of information, the person is not protected. Crimes that can typically be committed during acquisition are theft, trespassing, data breach, espionage or unauthorized position with secret information.

Who administers the whistleblower system?

TechTribe’s reporting channel is a secure system provided by TechTribe independent party Freja Partner (”Freja”). Freja’s whistleblower service is completely independent from TechTribe’s intranet and external website and can receive reports 24 hours a day.

The reporting person can choose to report anonymously or to appear with their personal data. No account registration is needed to make a report, but it facilitates further investigation of the case and/or follow-up of the case’s status. To ensure the reporting person’s anonymity, Freja does not save IP addresses or other metadata. The system also protects the report and any information about the person or persons whose identity appears in the report.

How is reporting done?

A report is submitted by the person who wants to report filling in an electronic form in Freja’s Whistleblowing Service.
If the reporting person wishes to continue the dialogue and/or follow the status of the case, the reporting person is assigned a unique case number and password to be able to follow the case
Freja’s Whistleblowing Service. The data needs to be saved securely. Freja’s reception unit receives the case (and confirms receipt if the person who reported created an account for further contact or provided contact information in another way).
An initial assessment of the case is made.
The report and the initial assessment are forwarded to the elected representatives within TechTribe for further handling and action planning. Freja ensures that a report is not forwarded to anyone within TechTribe affected by the report.
TechTribe will decide on any action.
Feedback is provided to the person who reported, if the person created an account or provided contact information in another way.

Right to confirmation and feedback

The reporting person receives a confirmation from Freja that the report has been received within seven days unless the reporting person has waived this confirmation or if there is reason to believe that a confirmation would reveal the person’s identity.

Freja will provide reasonable feedback to the reporting person as to what actions have been taken and why within three months of receiving a report (or if no acknowledgment of receipt has been provided, seven days of receiving the report).

Different ways to report misconduct

TechTribe’s whistleblower channel is not intended to replace other reporting channels, but functions as a complement to these. The person who wants to report a misconduct can himself choose the reporting channel that is most appropriate depending on the circumstances and his own assessment of the risk of reprisals. Other possible channels are:

Internal reporting in other ways (for example immediate manager),
Other external whistleblower channels. The government has appointed a number of authorities that, through external reporting channels, must receive, follow up and provide feedback on reports of misconduct within their designated area of responsibility. The full list of responsible authorities can be found below in the Ordinance on the Protection of Persons Reporting Misconduct (2021:949).

Ordinance (2021:949) on the protection of persons who report misconduct.

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