1. Introduction and purpose
This page describes the Easybell procedure for the reporting of serious offences through the Easybell / dsnty Speak Up whistleblowing system.
The aims of Easybell / dsnty Speak Up and this guide are:
- To encourage persons to report suspected serious wrongdoing as soon as possible in the knowledge that their concerns will be taken seriously and investigated as appropriate and that their confidentiality will be respected.
- To provide persons with guidance as to how to raise those concerns.
- To reassure persons that they should be able to raise genuine concerns without fear of reprisals, even if they turn out to be mistaken.
- To set out the procedure for handling reports made by whistleblowers through Easybell’s whistleblower system.
The whistleblowing system may be used by the following persons to report serious offences or suspected serious offences:
- All workers in a professional context, i.e. employees, self-employed workers, volunteers, trainees, interns, directors, members of the board of Easybell, shareholders of Easybell and members of supervisory bodies;
- Independent third-party contractors, subcontractors and suppliers;
- Ex-workers and future workers, being all persons reporting breaches in a professional as opposed to private context.
Easybell encourages that serious offences are reported through Easybell Speak Up. However, it is emphasized that the system is a voluntary alternative to the ordinary internal channels, e.g. local management, local HR responsible, group management or group legal.
Easybell encourages its staff to use the whistleblowing system and to protect all whistleblowers who makes a report in a good faith etc. Such persons will not be subjected to any adverse treatment or adverse consequence.
The whistleblowing system is not an emergency hotline. Any issues that constitute immediate threats i.e. where there is a threat to health, life etc. should be reported through the ordinary emergency channels.
Types of serious misconduct in the workplace:
- Conflict of interest
- Policy/procedure breach
- Sexual Harassment
- Violation of the Code of Conduct
Persons can report misconduct through Easybell Speak Up at
Persons can report misconduct in multiple languages: German, Danish, Dutch, English, French and Swedish.
The whistleblowing service is independent and outsourced to Deloitte, as an external and independent third-party to Easybell. The service is available 24/7.
Upon screening of the report and assessment, the report is forwarded to a Easybell representative, who will investigate the case further.
Persons, who are reporting an incident/misconduct, are free to choose the anonymity level they prefer:
- Persons can choose to be fully known and provide information on their identity and involvement in the incident that is being reported.
- Persons can choose to share their identity or details with Deloitte, as a third-party, which will not share this information with Easybell.
- Persons can choose to remain totally anonymous and ensure their safety by not disclosing their identity to Easybell or Deloitte. It is important to provide as much information as possible, to avoid misinformation, however, the whistleblower will be able to communicate through the Halo platform and provide necessary clarifications to their case, without the necessity to share their private information in the disclosure.
As per the directives from the European Council, Easybell has the obligation to respond and follow up to the whistleblowers’ reports within 3 months (with the possibility of extending this to 6 months for external channels in duly justified cases).
Easybell’s representatives will revert with feedback regarding the progress, or the decision taken in regards to the misconduct reported.
Persons can access the Easybell Speak Up platform freely, with no limitations required. Upon submission of their disclosure, they will be provided with username and password, to further access the website and read feedback on their case, or if applicable, add new information and evidence to their previous reported file.
To help make Easybell a fair, safe and honest place to work. Misconduct can have a negative effect on the work environment and reputation. By reporting misconduct you can help save money by detecting fraud and ensure people are secure and safe in the work environment.
Whether you want to stay anonymous or not when you contact Easybell Speak Up is up to you - you can stay anonymous or you can tell Easybell Speak Up who you are, although you are encouraged to identify yourself as this frequently makes the investigation and resolution process easier. Sometimes you may not be able to remain anonymous as your identity may be apparent to Easybell Speak Up or Easybell from the information you give.
Easybell Speak Up will try and ensure that you remain anonymous if you choose to do so. Easybell Speak Up will keep any information you give about yourself confidential within Easybell Speak Up. Easybell Speak Up will also disclose it if required by law to do so.
You are not required to provide your name to Easybell Speak Up unless you wish to do so. Your report will be known only by a reference number unless you choose to tell Easybell Speak Up your name.
Tell Easybell Speak Up as much as you can. For example:
- Names of people involved
- Names of any witnesses
- Date, time and location of the misconduct
- Details of any proof
- Money or assets involved
- How often the incident has happened
Most cases reported are uncovered through tips from honest people who are not sure of their facts. It is not expected you will know every detail. Reporting what you do know is enough.
Once you have made your report, you will not need to be involved in the report any further. However, if you have new or additional information, or would like to make an adjustment to a previous report, you can log onto the website with your reference number and password provided when you submit your initial report. Alternatively, you can contact the service and quote the reference number.
Easybell Speak Up will provide a report to a dedicated representative at Easybell within one business day of your report. Of course, if you report something of critical importance to Easybell Speak Up then it will be reported to Easybell immediately.
No, there is no reward for reporting misconduct to Easybell Speak Up.
If there are reasonable grounds to believe that the whistleblower’s information is true at the time of reporting and the information falls within the scope of the Whistleblowing Directive, Easybell shall protect against potential retaliation the persons who correctly reported such information in accordance with applicable law.
You can contact Easybell Speak Up as many times as you want to report suspected misconduct.
The information reported to Easybell Speak Up is forwarded to the Easybell representative who is responsible for addressing misconduct. If he or she decides action is necessary, then they may notify the appropriate law enforcement agency if this is appropriate.
Whether there is an investigation depends on a number of factors including the information provided, the details, documentation and Easybell company policy. Easybell will decide what action is required when they receive the report. All reports on material matters will be brought to the attention of the Group's internal audit committee at its regular meetings.
When you contact Easybell Speak Up your personal details will be collected should you wish to provide them, as well as any other relevant information about anyone else involved in the conduct.
Easybell Speak Up will only use and disclose personal information in providing this service to you and Easybell. Easybell Speak Up will disclose the information it collects to Easybell so they can act on your report as and when required by law or regulatory authority.