Block Zero aims to keep a positive, healthy and open culture, where every employee has the responsibility to follow policies, regulations and act ethically. If situations arise where there are conflicts with these principals the first line to handle the matter is to talk to each other or to someone in a management position that can help resolve the situation. For the special cases where that is not an option we cooperate with Whitepaper Advisors ("WPA") and any employee or direct stakeholder can file cases in their system “Trumpet”.
This policy describes what and how reports can be made in Trumpet.
Why Whistleblowing is important
For Block Zero, it is important that actions that violate laws, regulations, internal rules and guidelines are known as early as possible so that the risk of personal, material and immaterial damages as well as damages to our reputation is minimised. Through this policy, whistleblowers, who are prepared to signal serious issues or irregularities, should know that they are an important resource, which is why we strive to ensure a climate where whistleblowers feel that they can report irregularities safely and without fear.
The first option to report issues and problems, including serious misconduct, is always through the management structure in Block Zero. If for some reason you do not consider it appropriate to report the matter to the immediate manager, it is also possible to turn to another person in a managerial position.
In the event that you have information that a person in a key or senior position (eg a board member or person in a managerial position) has been involved in criminal activities or in any other serious irregularity and you have good reason to assume that your fears will not be dealt with properly, you can instead make your report via Trumpet.
A more extensive list of the values and code of conduct that we strive to adhere to when doing business can be found in our values
Who can blow the whistle?
A report through Trumpet can be submitted by anyone who in any way represents Block Zero. This includes board members, all employees (permanent employees, trial employees, project employees, either full-time and part-time), trainees and resource staff. But also employees of suppliers, consultants and partners have this opportunity.
What can be reported?
A report via the whistleblower system must be based on concrete suspicions. You do not have to have proof of your suspicion, but no accusation may be made with malicious intent or with the knowledge that the accusation is false. False or malicious accusations are a serious violation of the employment contract.
In order for a report to be reported via Trumpet, it is necessary that there are concrete suspicions about an event that meets both criteria below:
- that it refers to a serious irregularity
- that the irregularity has been committed by a key person in Block Zero
An issue that meets both of the above criteria is referred to for qualified reporting or whistleblowing.
Serious irregularities means
- economic crime such as bribery, theft, fraud and counterfeiting, corruption, accounting offenses and other breaches of accounting and tax laws, and
- other serious irregularities concerning the vital interests of Block Zero or the lives and health of individuals, such as, for example, serious environmental crimes, major deficiencies in workplace safety and serious forms of discrimination and harassment.
Block Zero key persons refers to
- Board member
What should not be reported?
Types of matters other than those set out above shall be handled by reporting to the immediate manager or to another organisationally related person in a senior position.
Matters that should not be handled in Trumpet can be, for example:
- events that do not constitute a serious irregularity, such as general dissatisfaction with the way the business is conducted or with leadership, salary or other personnel matters
- serious irregularities committed by persons who are not key persons within Block Zero
A notification that does not meet the criteria for a notification in the whistleblower system is referred to within the framework as an unqualified notification. An unqualified notification will not be handled as a whistleblower report. If you make an unqualified report, you will be informed and the report will be deleted from Trumpet within three weeks.
How is a report made?
Suspicions of serious irregularity can be reported anonymously and confidentially to Trumpet via the website, by phone or letter. Reporting can be done in either Swedish and English.
Reporting via website
A report via Trumpet's website > [Report A Case] > and then use our organisational code wbbz20.
Report by phone
Filing by phone is made by calling +46 20 103091.
Report by letter
Filing by mail is made using the address:
Trumpet, Box 479, 201 24 Malmö.
What should a report contain?
In the report, you must describe all the facts and develop your statement as accurately and in detail as possible. Also explain everything that may be relevant to the report. The information should be as accurate and detailed as possible. A notification shall, if possible, contain at least the following information:
- what it concerns
- who is involved
- where the incident took place
- if it was a one-time occurrence or if the problem is ongoing or recurring
Handling of registration
Reports made through Trumpet are handled by a limited group of people who are subject to strict confidentiality. This includes:
- specially qualified staff at WPA
- Block Zero’s "Whistleblower Committee".
Our CEO will also receive a notification unless the notification relates to them specifically.
A report will be handled respectfully, carefully, with confidentiality, and with regard to the integrity of all individuals involved. A report will also be handled promptly and decisions on measures will be made as soon as possible, but never at the expense of quality or legal certainty for the individual or individuals who are the subject of the report.
Further information on how to handle a report can be found in our Whistleblowing process
Measures to protect the notifier
Notifications in the whistleblower system can be made either:
- completely anonymous
- anonymously in relation to Block Zero, but openly in relation to WPA
- open in relation to both WPA and Block Zero’s Whistleblower Committee
Communication can take place while maintaining anonymity and confidentiality through Trumpet's website.
If the Reporter chooses to be open with their identity, the personal information will be handled with secrecy and kept secret as far as is legally possible. In the event of a report leading to a police report or other legal action, Block Zero or WPA may, however, be obliged to disclose the Reporter's personal data (for example because of an obligation to testify in a trial). In such a situation, the Reporter will always be informed before their personal data is passed on.
As a result, persons who make a report will not suffer any negative consequences regarding work tasks, terms of employment or the work situation in general, neither at the time of the report nor at a later stage.
If a Reporter considers that they have been subjected to reprisals despite the fact that the report was made in good faith, after having reported or participated in an investigation, that in itself is a serious issue that can be reported to any manager within Block Zero. All such reports will be investigated in confidence.
Information about the processing of personal data
Personal data provided via Trumpet is handled in accordance with the provisions of GDPR, other applicable legislation, and Block Zero’s personal data policy in force at any given time. For such information, Block Zero is the personal data controller and WPA personal data assistant. This includes the Reporter's personal information if they choose to be open to the Whistleblower Committee.
If the Reporter chooses to be anonymous in relation to the Whistleblower Committee, but open to WPA, WPA will be responsible for personal data for the Reporter's personal data. This information will be handled in accordance with WPA's personal data policy. If the Reporter at a later time chooses to be open also to the Whistleblower Committee, the personal data responsibility will be transferred to Block Zero, whereby WPA will be the personal data assistant for this information as described above