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Procedure for the COWI Whistleblower

Photo: Niclas Jessen

What can be reported through the COWI Whistleblower, and how should I use it? Please find answers to these questions and more in the procedure for COWI Whistleblower below.

 

  • Who can use the COWI Whistleblower
  • Protection of users acting in good faith
  • Receipt of report and investigation
  • Information to the employee
  • Violation of the COWI Whistleblower procedure 
  • Data privacy and data security

Please note that in France, Germany, Belgium, Sweden, the Netherlands, Portugal and Spain the data privacy laws require a limitation of the categories. If you would like to report an issue that is not available on the website, please talk to your manager, the next line manager or the HR Partner.

Who can use the COWI Whistleblower

The COWI Whistleblower is primarily set up for COWI's employees if the normal channels of communications are deemed, or experienced, not to be appropriate in the specific case. However, if for some reason the user feels uncomfortable doing so, he or she can file a report through the homepage or by telephone. The COWI Whistleblower is open to be used by any stakeholder.

COWI encourages users of the COWI Whistleblower to identify themselves, as this will make it easier to look into their concern. However, users can also remain anonymous and their name will not be registered. All users will be provided with a password and can track their reports and responses online via the Internet site, using their personal access code. It is particularly important for anonymous users to log in and check their reports as this will be the only channel available for COWI to ask for additional information.

Protection of users acting in good faith

Anyone filing a concern, a complaint or a report of a violation or suspected violation must be acting in good faith and have reasonable grounds for believing that the information disclosed is true and accurate.

COWI will not discharge, demote, suspend, threaten, harass or in any manner discriminate against any employee in the terms and conditions of employment based upon any lawful actions of an employee with respect to good faith reporting of concerns, complaints or reports of violations or suspected violations.

If any user of the COWI Whistleblower believes that he/she has been retaliated against for reporting or participating in an investigation, he/she should immediately report such perceived retaliation to the Group Compliance Manager. All such reports will also be investigated confidentially to the extent possible. 

If the user of the COWI Whistleblower knowingly files misleading or false concerns, complaints or reports, without a reasonable belief as to the truth or accuracy of the claim, he or she will not be protected by this procedure for use of the COWI Whistleblower. Misuse of the COWI Whistleblower will be addressed in the appropriate manner.

Receipt of report and investigation

The submission will be received in the Ethics Point system, operated by Navex, a third party company hosting the whistleblowing database. Navex will screen incoming submissions and forward the submissions to COWI's Group Compliance Manager, John de Meza Espersen.

The Group Compliance Manager will deal with all submissions and if necessary involve experts and regional representatives to ensure that the necessary skills and local expertise are present to conduct an independent, professional and objective investigation.

All submissions will be considered carefully and it will be assessed whether the submission is unfounded and should be deleted from the records, whether it is necessary to gather more information or whether a formal investigation is necessary.

The investigation will be conducted in a confidential manner to the maximum extent consistent with a thorough and complete investigation.

A compiling report of investigated and unfounded messages shall be submitted to the Executive Board once a year and to the Board of Directors once a year. 

If the submission concerns the Group Compliance Manager, the General Counsel or any members of the Executive Board, the submission will be referred to and handled by the Chairman of the Board of Directors. Reports about the Chairman will be handled by COWI's external lawyer.

Information to the employee

Employees that are subject to a formal investigation will be informed appropriately. The information to the employee will take due consideration to the confidential nature of the information and ensure that it does not compromise the investigation.

Information to users of the COWI Whistleblower: All users of the COWI Whistleblower will be provided with a unique report key and asked to create a password. This allows the user to follow-up on their report and answer additional online questions from the Compliance Team. All correspondence remains confidential.

Violation of the COWI Whistleblower procedure

 

Appropriate actions proportionate with the violation will be taken. This can have consequences for the employee relation and may be reported to the appropriate authorities.

If authorities investigate a crime, COWI will disclose information in accordance with the law.

Data privacy and data security 

All personal data will be processed in accordance with COWI's Policy for Whistleblowing and Data Privacy, which includes applicable legislation and principles of proportionality and reasonable measures.

Unfounded complaints will be deleted from the database immediately. If a submission is investigated it will be deleted from the database as soon as possible after the investigation is closed, and no later than two months after the case is closed.

If COWI decides to take disciplinary action against an employee the information will be kept for five years in the personnel files of the employee. If the case is transferred to the authorities, the information will be kept until the authorities have closed the case.

Navex will store the data and takes all reasonable precautions to protect personal information in its possession from loss, misuse and unauthorised access, disclosure, alteration and destruction. COWI will have independent third party verification of the security at Navex on an annual basis.

All communication between the Ethics Point system and a user's web browser is conducted using 128 bit SSL encryption.

LAST UPDATED: 28.08.2017