Whistleblowing Policy
For Navigent Group and its subsidiaries
What can be reported
The purpose of the whistleblowing function is to enable reporting of serious misconduct within the organization that is of public interest to bring to light.
Examples of such misconduct include:
- Corruption, bribery or financial crime
- Serious deficiencies in work environment or safety
- Discrimination, harassment or retaliation
- Serious violations of laws, internal policies or ethical guidelines
- Environmental crimes or other serious violations that may harm the public or the organization
Personal complaints that only concern one’s own work situation or a conflict with a colleague should primarily be handled through our regular HR procedures (see the section “How other matters are reported”).
Who can report
The right to whistleblow applies to:
- Employees and former employees
- Job applicants
- Consultants, interns, and hired staff
- Suppliers, subcontractors, and their employees
- Board members and other individuals with assignments for the organization
The protection under the Whistleblower Act also applies if the reported information later turns out to be incorrect, as long as the report was made in good faith and with reasonable grounds to believe the information was true.
How other matters are reported
Issues concerning one’s own employment such as work environment, salary, job satisfaction or cooperation between colleagues should not be reported through the whistleblowing channel.
Such matters should instead be handled through:
- Your immediate manager
- The HR department
These matters fall outside the protection of the Whistleblower Act but are still important to handle through our ordinary internal processes.
Reporting
Reports can be submitted via the organization’s whistleblowing channel: Whistleblowing
Reports can be made in writing, verbally or through a personal meeting upon request.
Reporting can be done anonymously or with your name.To enable fair and effective handling the report should, if possible, include
To enable fair and effective handling the report should, if possible, include:
- A description of what has happened
- Date(s) and location(s)
- Individuals involved or affected
- Any supporting documents or evidence
Who receives the report
The organization has designated HR and the Operations and Development coordinator as the receiving function for whistleblowing reports.
The recipient is responsible for:
- Confirming receipt within two weeks
- Handling the case within two months
- Assessing whether the case falls under the Whistleblower Act
- Initiating and following up on the investigation objectively and confidentially
- Documenting the process in accordance with applicable regulations
Feedback
The person who submitted a report should, if contact information is available, receive feedback within two months of the confirmation of receipt.
The feedback should include information about:
- Actions taken or planned
- The status of the case (to the extent that it can be shared without compromising the investigation or the individuals involved)
Personal data and anonymity
All personal data processed within the whistleblowing function is handled in accordance with the General Data Protection Regulation (GDPR).
Information is stored only as long as necessary to investigate and follow up on the case.
The reporter may choose to remain anonymous; however, this may limit the ability to provide feedback.
Only authorized personnel have access to submitted reports and confidentiality is strictly maintained.
Misuse
The whistleblowing function must not be used to intentionally submit false or misleading information.
Knowingly false reports may lead to disciplinary action or, in serious cases, legal consequences.
Responsibility
Management is responsible for ensuring that the whistleblowing function is well-known, accessible and safe to use.
The receiving function is responsible for the correct handling of incoming reports.
All employees and partners share a collective responsibility to act ethically and report serious misconduct when it is discovered.