Whistleblowing

Whistleblowing is a procedure that is voluntarily implemented by Vattenfall and which allows employees, contractors, suppliers, partners and other external and internal stakeholders to report serious irregularities and other complaints at Vattenfall.

Why

It is of great importance to Vattenfall to protect the company, its employees, suppliers, customers, the environment and society as a whole against serious irregularities that might be conducted by Vattenfall or Vattenfall's employees (including temporary staff). If serious irregularities can be found at an early stage, Vattenfall has a better possibility to prevent risks and limit the damage to the benefit not only of Vattenfall but also of its employees and other stakeholders. Therefore, Vattenfall has established a possibility to report serious irregularities through several different reporting lines.

What can be reported?

Examples of serious violations that could be reported:

• Bribery and corruption
• Fraud
• Conflict of interest
• Unfair competition practices
• Improper procurement procedure
• Improper use of inside information
• Theft and embezzlement
• Harassment
• Breaches of human rights
• Etc.

How to report a concern

1. Vattenfall’s web-based Whistleblowing Channel is available 24/7, 365 days a year. By reporting through the Whistleblowing Channel, you have the option to remain anonymous.
2. You may also report a concern directly to the Group Internal Audit department or any of the Whistleblowing coordinators at Vattenfall either by e-mail or phone (see the contact details below).
3. As a complement to the above two reporting lines, a whistleblowing report could also be made to one of Vattenfall’s external ombudspersons (see the contact details below). The ombudspersons are experienced lawyers independent from the Vattenfall Group. They shall act in accordance with professional discretion. Also such a report could be made anonymously in relation to Vattenfall.
4. Cases covered by the Swedish Act on the Protection of Persons Reporting Irregularities (2021:890) can also be reported to the competent authority, and where applicable to competent EU bodies. In Sweden, the Swedish Work Environment Authority is responsible for compiling which authorities handle whistleblower cases.

What happens after I have sent my report?

We will acknowledge receipt of your report as soon as practically possible and no later than 10 working days from the day of the report. All reported concerns are taken seriously and we will take appropriate action on each report. You may be asked to provide additional information if needed. Please remember that you could always remain anonymous for as long as you want throughout this dialogue if you choose to report via the Whistleblowing Channel or to one of the external ombudspersons.

The whistleblowing investigations are conducted by national investigation teams structured to suit local needs and the type of suspected irregularity. The investigation teams typically include representatives from Group Internal Audit and the Legal departments of Vattenfall, with support from other staff functions when required (such as Human Resources). All sensitive information related to an investigation, including any personal data of the whistleblower, is treated as strictly confidential.

If a breach of law, a serious violation of the Vattenfall Code of Conduct and Integrity or any other internal regulation is deemed to have taken place, the management of the relevant Vattenfall Business Unit or Staff Function concerned by the incident will be recommended appropriate follow-up measures. Such measures typically concern improved internal routines and working procedures, but also disciplinary sanctions (including formal warnings, dismissals and terminations of hire) in case of more severe misconduct. You as a whistleblower will always be kept informed about the conclusions of the investigation as soon as practically possible.

If the report is made to an external ombudsperson, he or she will conduct a first check incorporating an evaluation of the matter in relation to the Vattenfall Code of Conduct and Integrity and applicable national legislation. All personal data and other information received by the ombudsperson from you will be handled strictly confidential until the point you explicitly allow the ombudsperson to pass on all or part of the information to the ombudsperson’s contact person at Vattenfall for further investigation.

Non-retaliation commitment

It is strictly prohibited for all Vattenfall employees and other representatives to attempt to determine the identity of a whistleblower. Vattenfall also prohibits all retaliation of any type against a whistleblower who have brought forward a concern in good faith. Any such confirmed violations may lead to disciplinary sanctions, including the possibility of dismissal and termination of hire.