Whistleblower
RM Fintech A/S operates a whistleblower scheme where serious matters can be reported confidentially.
Who can report
Employees, former employees, applicants, business partners and suppliers.
What can be reported
Breaches of EU law and serious matters, including bribery, fraud, and serious breaches of working environment or environmental regulations.
How to report
Reports are submitted via the form on this page. You choose the type of concern, describe the incident and may remain completely anonymous. Reports are stored in a closed mailbox accessible only to the person responsible for the scheme, and you receive a reference once the report is registered.
Purpose of the whistleblower scheme
RM Fintech A/S has established a whistleblower scheme that gives employees and others associated with the company the opportunity to report serious matters and suspicions of illegal activity or serious irregularities, without having to raise the matter through the ordinary management hierarchy if that is perceived as a barrier.
The scheme is intended to support a culture in which employees can safely draw attention to matters that concern them, without fear of negative consequences, and in which the company has a genuine opportunity to detect and correct errors and irregularities before they develop into larger problems.
The whistleblower scheme is a supplement to the ordinary, open dialogue within the organisation and does not replace the everyday opportunity to raise questions and concerns directly with an immediate manager, but provides an additional channel for situations where that is not perceived as a viable path.
Who can report, and what can be reported
The scheme can be used by employees, former employees, suppliers, business partners and others who, by virtue of their work-related connection to RM Fintech A/S, have become aware of matters that can be reported under the scheme. The scheme is not intended for ordinary personnel matters, unless these are of a serious nature.
Suspicions can be reported regarding matters such as violations of legislation, serious breaches of internal guidelines, corruption, bribery, fraud, serious safety-related matters, or serious breaches of environmental and working environment rules, where the matter is of a certain seriousness or general interest to the company.
General dissatisfaction with working relationships, management style or similar matters that do not in themselves constitute a violation of legislation or serious internal guidelines are best handled through the usual internal channels and are not expected to be reported through the whistleblower scheme.
How to make a report
Reports can be made in writing or verbally through the channel made available by the company for this purpose, and there is the option to report anonymously if the reporting person so wishes. However, we encourage the reporter, if possible, to provide sufficient information for the matter to be investigated effectively.
A report should, as far as possible, include a description of the specific matter, when it was observed, who is involved, and any documentation supporting the suspicion. The more specific the information, the better the company's ability to investigate the matter thoroughly.
Reports falling outside the scope of the scheme are, where possible, forwarded to the relevant internal function for ordinary case handling, unless the reporter wishes the matter to be handled confidentially within the whistleblower scheme alone.
Confidentiality and protection against retaliation
The identity of a person making a report in good faith is treated confidentially and is not disclosed to anyone other than those necessary to handle the case, unless the reporter consents to disclosure, or disclosure is required by law.
Persons who, in good faith, report a matter through the scheme are protected against retaliation as a result of the report, including dismissal, transfer or other unfavourable treatment, in accordance with the legislation protecting whistleblowers.
Deliberately false reports, where the reporter knows or should know that the matter is untrue, are not covered by the protection and may, in serious cases, have consequences for the person who made the report, in accordance with applicable rules.
Report a concern
Fill in the form below. You decide whether to provide contact details or to report completely anonymously. Reports are stored in a closed mailbox accessible only to the person responsible for the scheme, and you receive a reference once the report is registered.
Handling of reports
Reports are received and handled by a designated function within the company with the necessary independence to investigate the matter impartially, regardless of which department or person the report concerns. If a report concerns persons within the designated function itself, the matter is handled through another, independent channel.
The reporter receives confirmation that the report has been received within the deadline set by law, and is subsequently informed of the overall steps being taken in the case, to the extent this can be done without compromising the investigation or the rights of other persons involved.
The investigation is organised so that it is proportionate to the seriousness of the matter, and external legal or other professional assistance is involved if the complexity or seriousness of the case warrants it, including in cases that may have criminal law aspects.
Follow-up and improvement of internal procedures
Once a report has been investigated, a decision is made on whether specific measures are needed, including personnel consequences, changes to internal procedures, or additional controls, to prevent a similar matter from recurring in the future.
Lessons learned from handled cases, in anonymised and aggregated form, are used to continuously improve the company's internal controls and guidelines, without compromising the confidentiality of the individual case or the persons involved.
Management is informed periodically about the general use of the scheme, including the number of reports and the main features of the matters handled, in order to assess whether the scheme is working as intended and whether adjustments are needed.
Entry into force, availability and legal approval
The whistleblower scheme is available to all employees and relevant external parties, and information on how to use the scheme is made easily accessible, both during onboarding of new employees and on an ongoing basis through the company's internal communication.
The scheme is continuously evaluated to ensure it continues to meet the requirements arising from applicable legislation on the protection of whistleblowers, and to ensure it functions in practice, not only on paper.
This description of the whistleblower scheme constitutes the company's practical basis for the scheme's use. Final legal approval of whether the scheme in all respects complies with applicable legislation is carried out by the company's advisor.
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