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Arctic Law Greenland ApS and Timersoqatigiit Kattuffiat have entered into an agreement for the administration and operation of the whistleblower scheme,
The purpose of the whistleblower scheme in Timersoqatigiit Kattuffiat is to ensure that an independent party can receive and process information regarding misconduct or irregularities that cannot be addressed within the existing organizational structure.
Employees, board members, or athletes in the organization's member associations who become aware of fraud or other significant irregularities within the organization may report their knowledge of such matters. This applies to circumstances that are not considered capable of being handled through the existing management systems, including through the Secretariat of Timersoqatigiit Kattuffiat.
All employees, board members, active athletes, and leaders within the organization's member associations are covered by the whistleblower scheme and may therefore both report matters through the system and be subject to investigation under the scheme.
Timersoqatigiit Kattuffiat encourages you to report illegal conduct, violations, or suspected serious misconduct relating to matters that may affect Timersoqatigiit Kattuffiat as a whole or the life and health of individuals, for example, violations of Timersoqatigiit Kattuffiat’s internal policies.
It is not possible to provide an exhaustive list of activities that may fall within these categories. Timersoqatigiit Kattuffiat expects you to report any suspicions you may have, in good faith, regarding matters such as:
A) Criminal offences
B) The use of unfair or deceptive actions and practices, including:
C) Discrimination or harassment, including sexual harassment
D) Unlawful conduct relating to accounting, internal accounting controls, auditing and financial matters, including fraud, embezzlement, forgery, and accounting manipulation
E) Serious breaches of environmental regulations and environmental pollution
F) Serious violations of occupational health and safety requirements and workplace safety regulations
G) Violations of Timersoqatigiit Kattuffiat’s code of conduct, such as violent behavior or threats against others
H) Violations of Timersoqatigiit Kattuffiat’s guidelines on the use of alcohol, drugs, and doping substances, where such violations may pose a significant risk to the life and health of individuals
I) Attempts to prevent any of the above matters from being brought to light
The following matters cannot be reported through the whistleblower scheme and include less serious issues such as:
A) Complaints concerning day-to-day personnel matters or routine employment issues, such as conflicts between employees and/or managers
B) Matters relating to trade unions or employee absence
C) Violations of Timersoqatigiit Kattuffiat’s guidelines on the use of alcohol and drugs, unless there is a risk that such violations could result in breaches of safety laws, policies, or similar requirements
The matters mentioned above should instead be reported directly to the Secretary General.
Timersoqatigiit Kattuffiat has entered into a cooperation agreement with the law firm Arctic Law Greenland. Through their website, www.arcticlawgreenland.gl, you can access the whistleblower system and submit a report online using Timersoqatigiit Kattuffiat’s general login credentials.
Your report will remain anonymous, and no electronic tracking will take place. We encourage you to provide a contact email address so that the law firm may, if necessary, ask supplementary questions. However, this is not a prerequisite for submitting a report.
The system allows you, as a whistleblower, to remain anonymous. However, you are encouraged to identify yourself, as this can significantly facilitate the investigation of the matter. If you choose to remain anonymous, neither the system administrator nor the case handlers will be able to trace your identity. It is nevertheless possible to communicate with you while maintaining your anonymity, as described in the section on reporting procedures.
Timersoqatigiit Kattuffiat understands that some individuals may be reluctant to disclose their identity, but we nonetheless encourage you to submit reports under your own name. If you choose to remain anonymous, the law firm and the Whistleblower Committee will still be able to contact you anonymously, provided that you supply an email address.
Please note, however, that if you use IT equipment or an internet connection owned by Timersoqatigiit Kattuffiat, it may theoretically be possible, through system logging, to identify the IP address and/or device ID from which the report was submitted.
To assess whether a report has merit, the following information will normally be valuable:
You should, to the greatest extent possible, focus on facts and avoid speculation or expressing personal opinions about the matter in question.
8.1. Appropriate Case Handler
Once a report has been submitted, the law firm will forward the report, together with its recommendation, to the Whistleblower Committee, which will immediately investigate the matter thoroughly and take the necessary steps in accordance with applicable legislation and the policies of .
The Whistleblower Committee of consists of:
As a general rule, cases are handled by the Whistleblower Committee. However, in certain situations, the case must be assigned to another case handler, as outlined below:
| Report concerns | Appropriate case handler |
|---|---|
| A member of the Whistleblower Committee | The Chairperson of the Board of |
| Members of the Board of Directors | The Chairperson of the Board of |
| The Chairperson of the Board of | The Secretary General of acting alone |
| Unclear circumstances | Determined by the Whistleblower Committee in consultation with the law firm |
In addition, the case handler may, when necessary, involve other parties in the process, such as the Secretariat, finance, IT, or legal advisors, depending on the nature of the report.
Any such involvement shall remain confidential, and the persons involved may not disclose information unless required by law, a court order, or a request from a competent public authority.
Both the case handler and any other parties involved in the matter must assess whether they are impartial and qualified to handle the case. This assessment shall be made according to generally applicable conflict-of-interest principles. If the case handler is deemed to have a conflict of interest, the case shall be transferred to the Secretary General or the Chairperson of the Board. If other parties involved, such as employees of the organization, are deemed to have a conflict of interest, the matter shall, where possible, be reassigned to another employee.
The Whistleblower Committee may at any time engage an external lawyer for advice, including advice regarding who should handle the case.
will conduct an initial assessment of the report and recommend any actions considered appropriate for determining whether a formal investigation should be initiated.
In this context, will assess, among other things, whether:
If the report does not meet these criteria, it will be deleted, and the reporting person will be referred to use ordinary reporting channels, unless the reporting person has opted out of communication.
Before deleting the report, , together with the Whistleblower Committee, will assess whether the matter concerns serious misconduct requiring the information to be reported to the police and/or, where relevant to , whether further internal investigation is necessary.
Investigation and Outcome. If a report cannot be immediately dismissed, it is not considered manifestly unfounded.
Where a report is not manifestly unfounded, a formal investigation of the reported matter will be initiated. As part of this process, relevant parties may be involved, such as Human Resources, occupational health and safety representatives, finance personnel, and any necessary legal advisors.
Where relevant, technical and digital evidence will be secured.
Interviews may also be conducted with employees and other relevant persons, as well as with the individual(s) who are the subject of the report. As a general rule, interviews will only be conducted after any relevant evidence has been secured. Interviews will either be recorded or documented in written minutes.
Based on the investigation, an investigation report will be prepared, concluding whether there is evidence that misconduct or irregularities have occurred.
The case handlers will then assess the potential consequences arising from the report. Such consequences may include:
The implementation of any sanctions will take place with the involvement of the relevant members of management within the organization.
If disciplinary proceedings are initiated against an individual, he or she shall be entitled to appeal the decision in accordance with applicable local complaint and appeal procedures, including, where relevant, through the involvement of the appropriate trade union or professional organization, and, naturally, through the courts.
Timersoqatigiit Kattuffiat does not tolerate any form of retaliation against, or punishment of, individuals who, in good faith, report concerns or assist in investigating violations under this Whistleblower Policy.
Accordingly, prohibits reprimands, reprisals, changes in job duties, changes in employee benefits, changes in reporting requirements, damage to the whistleblower’s career opportunities or reputation, threats to carry out any of the foregoing actions, or deliberate omissions intended to harm the whistleblower.
Individuals who knowingly and maliciously submit false reports against another person are not protected under this Whistleblower Policy. Persons who make reports in bad faith may be subject to civil, criminal, administrative, and disciplinary sanctions, including termination of employment.
Regardless of whether is aware of the identity of the reporting person, that identity will not be disclosed to the person concerned without the reporting person's consent, unless such disclosure is required in connection with civil or criminal proceedings.
11.1 When a case has been reported.
The Whistleblower Committee shall be notified whenever a case is reported through the whistleblower system, unless the report concerns one or more members of the Committee. In such cases, the Chairperson shall instead be informed, provided that the report has not been assessed as manifestly unfounded.
At the same time, information shall be provided as to whether the report has been assessed as manifestly unfounded or whether there are grounds for further investigation.
If the report is assessed as manifestly unfounded, the person concerned by the report shall be informed of the matter.
The individual who is the subject of the report will be provided with information regarding the allegations that have been reported. This information includes:
a) The conduct he or she is suspected of having engaged in;
b) The departments within that may receive information relating to the report;
c) How he or she may exercise the right of access to the report and the right to respond to the allegations; and
d) The rights available to him or her.
This information shall be provided as soon as possible and, as a general rule, no later than ten (10) days after it has been obtained. If there is a risk that providing such information could hinder an effective investigation of the allegations or compromise the collection of necessary evidence, the notification shall be postponed for as long as that risk exists.
If the report contains information about other identifiable individuals in addition to the person who is the subject of the report, those individuals shall also be informed accordingly, as described above. Such notification shall not include information identifying the person who is the subject of the report.
Notification of the outcome of the investigation.
Once an investigation report has been completed, the persons involved in the case, as well as the Chairperson of the Board, shall be informed of the outcome of the investigation.
Furthermore, it may be necessary to inform third parties of the allegations and the investigation, such as contractual partners, law enforcement authorities, or regulatory authorities, but only to the extent permitted or required under applicable law.
Information to the reporting person.
Unless the reporting person has submitted the report anonymously and has chosen not to communicate with the Whistleblower Committee, the reporting person will be informed that the report has been received and that the investigation has been concluded.
The reporting person should be aware that, depending on the circumstances of the case and applicable legal requirements, he or she may not be entitled to access detailed information or receive information regarding the outcome of the investigation carried out.
Right of access and rectification.
The persons who are the subject of a report, as well as the reporting person, have the right to access the information registered about them so that the data can be reviewed and corrected where it can be documented that the information is incorrect, inaccurate, incomplete, ambiguous, or outdated.
Where a request for access is granted, the data subject will be informed of:
a) The data being processed;
b) The purpose of the processing;
c) The categories of recipients of the data; and
d) Any available information concerning the source of the data.
However, the right of access does not apply where the individual's interest in obtaining the information must give way to overriding considerations of public or private interests, or where disclosure could prejudice the investigation of the case.
The employee who is the subject of a report has the right to request that a note be added to the case file stating that the employee believes certain information to be inaccurate, incomplete, ambiguous, or outdated.
Data storage and retention. All reports shall be stored securely, and access to reports shall be restricted to relevant authorized persons only. Electronic information shall be protected through the use of passwords, antivirus software, and firewalls. Physical records shall be kept in locked storage.
Where the information collected results in a disciplinary sanction being imposed on the reported employee, or where there are otherwise legitimate and necessary reasons to continue retaining information concerning that employee, the case handler shall ensure that such information is included in the employee’s personnel file.
Personal data processed under this Whistleblower Policy shall be retained only for as long as necessary for the investigation of the report and any subsequent proceedings.
If the outcome of the investigation is that there is no evidence that misconduct or irregularities have occurred, the personal data shall be deleted without undue delay and normally no later than two (2) months after the investigation has been concluded, provided that, where relevant, the information has first been submitted to .
If evidence is found that misconduct or irregularities have occurred, different retention periods may apply depending on the time limits governing the initiation of legal proceedings or the imposition of disciplinary sanctions against the person concerned, or, where a report has been made in bad faith, against the reporting person.
Personal data may be retained for a longer period where the information has been anonymized.
If you have any questions regarding this Whistleblower Policy, you may contact a member of the Whistleblower Committee.
