Procedure for use of Novozymes’ Whistleblower System and handling of reports
The Novozymes’ Whistleblower System has been established to substantiate and support Novozymes’ commitment to ensure responsible and ethical business behavior.
By introducing Novozymes’ Whistleblower System, Novozymes aims at increasing the likelihood of early detection of possible serious illegal or unethical misconduct, whereby Novozymes will be better equipped to minimize the damages of such misconduct and to establish the right preventive measures.
The purpose of this Whistleblower System Procedure is to establish the procedures for the use of the Whistleblower System and to answer the below questions. Each question is answered in the below sections of this page.
How to report?
Novozymes’ Whistleblower System provides for an opportunity to report concerns to designated recipients from anywhere in the world, 24/7/365, by filing an online reporting form. Reporting is possible in multiple languages.
The Whistleblower system is hosted by Got Ethics A/S, an independent party guaranteeing the system’s security and anonymity and is accessible through links on www.novozymes.com and on the Zymernet.
Got Ethics A/S has taken the necessary technical and organizational measures to prevent personal data from being accidentally or illegally destroyed or lost, and to prevent any unauthorized disclosure or misuse of the personal data.
The handling of personal data is in compliance with the law and good practices in the field and subject to strict controls and procedures.
Who can report?
Novozymes’ Whistleblower System is available to employees and board members in companies in the Novozymes group as well as customers, suppliers, business partners and other stakeholders.
When to report?
Novozymes encourages all employees to report knowledge or suspicions of serious illegal or unethical misconduct to Novozymes either through the regular channels of communication or, subject to the restrictions set forth below, by using the Whistleblower System.
The Novozymes’ Whistleblower System does not replace the existing reporting procedures, e.g. for employee reporting of excessive gifts or facilitation payments. Please see Novozymes’ employee booklet on business integrity “Bribery – no thanks!” for further instructions.
The Whistleblower System neither replaces the possibility to request a confidential conversation with your manager or your manager’s manager.
The Whistleblower System should be used only when the regular channels of communication appear inexpedient or inappropriate.
Novozymes does not tolerate misuse of the Whistleblower System, and you should only use the Whistleblower System for reporting in good faith of incidents of serious illegal or unethical misconduct within the restrictions set forth below, which you have reason to believe are true.
What to report?
In the whistleblower system, you can report serious matters such as
- Breach of insider rules
- Breach of competition law
- Violations of human rights and labor standards (e.g. harassment or discrimination)
- Breach of material accounting and auditing legislation
- Breach of environmental law
- Violations of export control laws and international trade sanctions
- Unsafe working conditions
- Other serious violations of law
In some countries, there are specific restrictions on what and how you can report. You will receive the relevant instructions on the reporting page, once you have identified your geographic location.
The Whistleblower System is not intended for employee concerns related to human resources (HR). For such matters, please contact your local management or the local department for People & Organization.
Should you wish to raise a concern falling outside the scope of the Whistleblower System, please use the regular communication channels or contact Novozymes’ General Counsel (Novozymes A/S, Krogshoejvej 36, DK-2880 Bagsvaerd, Denmark, Att.: General Counsel Mikkel Viltoft or email@example.com), Novozymes’ Ombudsperson or the responsible management as applicable and appropriate.
Who is responsible?
The Novozymes’ Whistleblower System is anchored in Novozymes’ Audit Committee, which assists the Board of Directors in monitoring aspects relating to accounting, auditing, and control.
Novozymes’ General Counsel acts as a secretary to the Audit Committee being responsible for receiving and reviewing incoming reports and for regular reporting on whistleblower reports received to the Audit Committee.
This applies to reports relating to employees in any company within the Novozymes group of companies.
The General Counsel is responsible for coordinating the processing and investigation of reports, including implicating the management of the relevant parts of Novozymes’ organization specifically.
Depending on the nature and the content of the report, the responsible Regional Finance Manager or the local management may be consulted or take over the investigation and follow-up, except in circumstances where the reported misconduct is a result of activities conducted by the Regional Finance Manager or local management.
Novozymes’ local department for People & Organization will be involved in all reports involving specific employees and their conditions of employment.
All processing of reports by the General Counsel is confidential to the maximum extent possible under applicable law and consistent with a thorough and complete investigation.
The report and information processed as part of the investigation may be transferred onwards to an external attorney or auditor in connection with the investigation or if the report results in a court case, a police report or if required by law.
Novozymes A/S, Krogshoejvej 36, DK-2880 Bagsvaerd, Denmark, is the responsible data controller under applicable data protection regulations in EU for for all reports involving employees of Novozymes A/S or in affiliates in EU. With respect to processing of reports involving employees of affiliates outside EU, the Novozymes company being the employer of the relevant employees is data controller and Novozymes A/S, Denmark, is data processor.
All companies in the Novozymes group of companies remain responsible under applicable national privacy and labor legislation towards their employees. To identify the corporate legal entity responsible in your country, please contact Legal (firstname.lastname@example.org).
How am I protected?
Protection of reporters in good faith
Any report you submit in good faith based on real concerns will help Novozymes protect the interests of Novozymes’ employees, customers, business partners, and other stakeholders.
- No retaliation: Novozymes does not tolerate retaliation or retribution against an employee for having made a report in good faith, reasonably believing that it was true.
- Confidentiality: Confidentiality of reports will be maintained to the maximum extent possible, consistent with a thorough investigation, the interests of the parties involved and Novozymes’ obligations under applicable law.
- Protection of identity: Novozymes will protect the identity of any person who in good faith files a report using the Whistleblower System to the extent consistent with applicable law.
- Anonymity: A report may also be submitted anonymously and unless the identity of the reporting person is disclosed via the content of the report, the identity of said person shall not be traced. An-yone having filed a report will be provided with the opportunity to set up a secure post box, which allows for subsequent communication with the said employee securely and without disclosing identity. However, for the purpose of investigation, disclosure of identity will be encouraged.
Protection of persons concerned by a report
- All serious reports will be subject to thorough and confidential evaluation and investigation.
- Any misuse of the Whistleblower System and any reports filed in bad faith will be sanctioned appropriately.
- All groundless reports will be dismissed and disregarded.
- All reports that cannot be substantiated will be deleted and disregarded.
- All other reports will be stored for only to the extent needed for the investigation, follow-up or documentation.
- Novozymes’ local department for People & Organization will be consulted with respect to any considerations regarding possible disciplinary or other sanctions.
Protection of personal data
The personal data being collected through or in connection to Novozymes’ Whistleblower System shall be handled in accordance with Novozymes’ Data Protection Policies. Employee Data Protection policy is available on Novozymes’ Legal Zymernet page and the Third Party Data Protection Policy is available on Novozymes.com as of April 2018.
Information collected in connection with a report submitted in the Whistleblower System shall be used for the investigation of the subject matter reported and shall not be used for a subsequent purpose not compatible with this purpose. Please be referred to sections “Purpose” and “Introduction” above.
Information about reports received, including personal information, may be transferred to affiliates in the Novozymes group of companies to the extent relevant for the investigation, and subject to inter-company agreements ensuring the appropriate data protection safeguards.
How will I know?
Any person who is subject to a formal investigation will be properly informed in due time in accordance with the person’s legal rights, taking into consideration the sensitive and confidential nature of the report and any possible risk of jeopardizing ongoing investigations.
What happens now?
When you file a report via Novozymes’ Whistleblower System, you are encouraged to remain available for subsequent communication. You ensure that by setting up a post box in accordance with the simple steps described on the reporting site.
When setting up the post box you will be provided with a case number and asked to choose a password. With the case number and password you can log on to the post box to read and submit messages.
Remember that if you file your report anonymously, Novozymes will only be able to communicate with you by leaving messages for you in the secure post box, so keep your case number and password safe.
Who can I contact?
If you have any questions about the Whistleblower System, please contact Novozymes General Counsel, Mikkel Viltoft (email@example.com) or Novozymes Chief Legal Compliance Officer, Britt-Mari Hauberg (firstname.lastname@example.org).