Whistleblower Policy for CIMPRO A/S

Purpose
To ensure that it is easy and safe to report legal violations, that such reports are followed up on, and that whistleblowers are protected against any reprisals in accordance with applicable laws and regulations, as well as in alignment with CIMPRO A/S’s policy, objectives, and other requirements.

Overview and Description
The whistleblower scheme includes:

  • A reporting channel
  • Procedure for handling reports
  • A whistleblower policy

 

CIMPRO A/S Whistleblower Unit – Reporting Channel
Reports can be submitted in writing through the following channel:

  • Reporting form on the website: www.cimpro.dk
    The form sends the report to both info@cimpro.dk and to the chairman of the board. This can be done anonymously or by providing a name and email (optional).

Groups eligible to submit information to the whistleblower scheme:

  • Employees at CIMPRO A/S
  • Suppliers, customers, and other business partners

 

Information that can be reported:
Whistleblowers can use the CIMPRO A/S whistleblower scheme to report any information, including knowledge or reasonable suspicion of actual or potential violations that have occurred or are likely to occur within CIMPRO A/S, as well as attempts to conceal such violations. This includes, but is not limited to:

  • Corruption
  • Bribery
  • Theft
  • Embezzlement
  • Fraud
  • Sexual harassment
  • Bullying or severe harassment, e.g., due to race, gender, colour, language, financial status, national or social origin, political or religious affiliation

 

A violation or issue is generally considered serious if it is in the public interest to bring it to light. Whistleblowers may report matters that have occurred or are expected to occur at CIMPRO A/S. It is required that the whistleblower believes in good faith that the information provided is accurate.

Information that CANNOT be reported:
Minor violations are not covered, nor are violations of accessory rules (e.g., failure to comply with documentation requirements).

Other matters, such as violations of internal guidelines on sick leave, smoking, alcohol, dress code, or private use of office supplies, as well as information about the whistleblower’s own employment, including disagreements with colleagues or difficulties in cooperation, are generally not considered serious violations.

Such matters should not be reported through the CIMPRO A/S whistleblower scheme unless they involve sexual harassment or other forms of severe harassment.

Handling of Reports
Reports submitted to the CIMPRO A/S whistleblower scheme are handled and followed up on by the chairman of the board.
The content and nature of the report determine how it will be addressed.

The whistleblower unit will first assess whether the report falls within the scope of the scheme. If it does not, or if the report is clearly unfounded, it will be dismissed. The whistleblower will be notified unless the report was submitted anonymously.

If the report falls within the legal scope, it will be processed. This may include the CIMPRO A/S whistleblower unit gathering further internal information, depending on the nature of the report. Additional dialogue with the whistleblower may also occur.

Examples of follow-up actions:

  • Initiation of an internal investigation
  • Notification of senior management or the board
  • Reporting to the police or relevant supervisory authority
  • Case closure due to lack of or insufficient evidence

 

Confidentiality and Data Handling
Employees connected to the CIMPRO A/S whistleblower unit are subject to strict confidentiality regarding the information in the reports.

Confidentiality only covers the information included in the report. If a case is initiated following a report, the other information collected in that context is not subject to confidentiality.

The CIMPRO A/S whistleblower unit will treat all reports as confidential wherever possible.

Information from a report is processed in accordance with Section 22 of the Whistleblower Act and the General Data Protection Regulation and the Data Protection Act. Under Section 22 of the Whistleblower Act, CIMPRO A/S may process personal data, including sensitive information and information about criminal offenses, if necessary to handle a report received through the CIMPRO A/S whistleblower scheme.

Information from a report may be disclosed, e.g., for the purpose of follow-up. If the whistleblower has provided an email address, they will be informed before any disclosure of their identity, unless it would jeopardize a related investigation or legal case—for example, if disclosure could result in the destruction of evidence, intimidation of witnesses, or if there is suspicion that the whistleblower knowingly submitted a false report.

Protection of Whistleblowers
A whistleblower must not be subjected to threats or attempts at retaliation for reporting or disclosing violations through the whistleblower scheme. It is also not permitted to obstruct or attempt to obstruct a whistleblower from reporting violations.

Retaliation includes any form of adverse treatment or consequence in response to a report that causes or could cause harm to the whistleblower.

The whistleblower cannot be held liable for reporting confidential information if they have reasonable grounds to believe (in good faith) that the information is necessary to disclose a serious violation or matter.

Any attempts by CIMPRO A/S employees or management to obstruct a whistleblower from reporting or to retaliate against a whistleblower acting in good faith will result in employment-related consequences.

Further Information
The Danish Ministry of Justice has prepared a guide for whistleblowers, serving as a resource for individuals considering submitting information. It provides a general overview of the Whistleblower Act, including schemes, reporting options, whistleblower protection, and rights.

The guide can be downloaded via the link or found on the Ministry of Justice’s website: www.jm.dk

 

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