With this notification form, you can report violations or neglect of European Union legislation or its national implementing legislation or other national legislation within or by the Witted Group ("Witted") in the areas of legislation defined in Section 1.4 below under  EU Whistleblowing Directive (EU 2019/1937) and related national legislation. Please note that whistleblower legislation and whistleblower protection apply only to certain matters. 

Our Whistleblower Reporting Channel is available for Witted’s employees and stakeholders regarding matters defined in the whistleblower legislation. However, anyone can use the Whistleblowing Reporting Channel to report other matters than those falling within the scope of whistleblower legislation. For example, anyone can use the service to report discrimination, harassment, bad behavior, dissatisfaction in the workplace or related matters. In such cases, the matter will be handled according to applicable guidelines and practices, rather than as a whistleblowing issue.

When making a notification, please note that intentionally reporting false information is punishable, and such a notification may result in liability for damages. The reporting channel is not to be used as a general feedback tool.

The processing of notifications is the responsibility of the designated Notification Processor ("Processor"). Only authorized personnel, who are Witted’s legal and designated persons from HR, are permitted to access the information contained in the notifications. Additionally, persons responsible for Witted's IT functions also have access to notifications to enable technical implementation of the reporting system, but those persons do not process the notifications themselves. If necessary for processing, Witted may also engage external experts to assess the notification and determine appropriate actions. In such cases, confidentiality obligations will apply to these external experts, and they will only have access to relevant data.

When making a report, please provide as much detail as possible about the alleged violation or neglect. If needed, the Processor may contact you for additional information, provided that you have submitted the report under your own name. After submitting a report, you will receive an acknowledgment of receipt from the Processor within seven (7) days. Within three (3) months of receiving the report, the Processor is obligated to inform you of the actions that will be taken based on the report. Reports may also be made anonymously, in which case the Processor is not required to send an acknowledgment of receipt or provide information on the measures that will be implemented.

Upon receiving notification, the Processor will decide whether to accept or decline it. If the notification is accepted, appropriate measures will be taken to investigate the matter. The Processor may reject the report if:

• The report is made in bad faith or is malicious.

• There is insufficient information to proceed with an investigation.

• The issue reported has already been resolved.

The following principles will be adhered to during the processing of notifications:

• The Processor, or anyone involved in the investigation process, will not attempt to identify the person who submitted an anonymous report.

• The report will not be investigated by anyone who may be involved in or connected to the alleged wrongdoing.

• Confidentiality will be maintained by all parties involved in the handling of whistleblowing reports.

If an individual involved in the investigation is named in the report, they will be excluded from the investigation process. 

Please note that if the matter reported is not covered by whistleblower legislation but is deemed appropriate, it will be handled according to the relevant guidelines and practices, depending on the nature of the issue.

1.4 Subject of breach or neglect

In accordance with the whistleblower legislation, breaches that fall within the scope of the whistleblowing channel include breaches of EU or national laws in a work-related context in the following areas:

• public procurement (excluding defense and security procurement);

• financial services, products and markets;

• prevention of money laundering and terrorist financing;

• product safety and compliance;

• transport safety;

• environmental protection;

• radiation and nuclear safety;

• food and feed safety or animal health and welfare;

• public health referred to in Article 168 of the Treaty on the Functioning of the European Union;

• consumer protection;

• protection of privacy and personal data;

• security of network and information systems;

• the financial management of the European Union or the implementation of expenditure or the collection of the Union's income or funds;

• granting, use or recovery of grants or state subsidies;

• competition rules; or

• tax rules of companies and entities or arrangements to obtain tax benefits