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Hampiðjan Group’s Procedure for Reporting (Whistleblowing) and Handling of Non-Conformities

 

1. Application

This Whistleblower Policy applies to everyone within the Hampiðjan Group, including all employees, leaders, and the Board of Directors. It also extends to companies that are part of the Hampiðjan Group and any affiliated persons, such as business partners and suppliers.

2. Importance of Notifying

All members of the Hampiðjan Group have the right and responsibility to report breaches or suspected breaches of legal and ethical commitments. Such breaches may include:

  • Danger to life and health
  • Threats to the climate or environment
  • Corruption or economic crime
  • Abuse of authority
  • Unsafe working conditions
  • Breach of personal data security

Reports concerning only an individual’s own employment situation are generally not considered whistleblowing unless they relate to the issues described above.

3. Procedure for Reporting Violations

3.1 Reporting

  • Reports should be made without undue delay from the incident occurring.
  • Employees may report anonymously, but providing a full name is encouraged as it can aid the investigation.
  • The report must explicitly state that it is intended to report a violation and include the date and time of the report, as well as the actual or potential breach being reported.
  • Reports should be forwarded to the ESG Director or the CEO of Hampiðjan Group. If the report involves them, it should be sent to the Chairman of the Board.
  • The ESG Director will inform and advise the CEO or the Chairman of the Board and notify them of any concerns related to accounting practices, reporting procedures, internal controls, or auditing.
  • Contact details can be found in Section 7: “Who shall I notify?”

3.2 The Investigation

  • Each report will be reviewed responsibly.
  • The decision on who will conduct the investigation depends on the nature of the violation and available resources. External resources may be used if necessary.
  • The aim is to complete the investigation and review the report within 60 days. The CEO will review the report, and a copy will be kept on file.
  • Any found violations will be addressed appropriately, including possible preventative measures, disciplinary sanctions, or termination of contracts.
  • Employees may face consequences such as warnings or termination if involved in serious breaches.
  • If a dispute arises over the reporting employee’s position, they will be granted legal aid at all court levels.

4. Personal Data

Information received under this policy may include sensitive personal data on both the whistleblower and those involved in the suspected misconduct. This information will be handled according to applicable data protection laws and retained only as long as necessary, unless required by law.

5. Confidentiality

Hampiðjan Group ensures a confidential mechanism for reporting illegal activities or serious misconduct while protecting the reputations of innocent parties. Investigations will be conducted discretely and thoroughly. Efforts will be made to keep the whistleblower’s identity confidential whenever possible.

6. Whistleblower Protection

Hampiðjan Group takes accusations seriously and encourages reporting within the organization before seeking external resolution. The policy includes:

  • Encouraging internal reporting of serious concerns before seeking external resolution.
  • Protecting individuals from adverse employment consequences, harassment, discrimination, or retaliation for good faith reporting.
  • Disciplinary actions for retaliating against someone who reported a violation in good faith.
  • Disciplinary actions for making intentionally false claims, which could include termination.
  • Trusting employees to report any legal or ethical breaches to the appropriate personnel.

7. Who shall I notify?

Hampiðjan Group encourages an open-door policy. Employees are encouraged to report concerns to their line manager unless inappropriate due to involvement or severity. Otherwise, reports should be sent to the ESG Director, the CEO, or the Chairman of the Board. Contact details are:

Role Name Telephone Email
ESG Director, Hampiðjan Group Marthe Amundsen Brodahl +47 45239596 whistleblower@hampidjan.is
CEO, Hampiðjan Group Hjörtur Erlendsson +354 530 3361 hjortur@hampidjan.is
Chairman of the Board, Hampiðjan Group Vilhjálmur Vilhjálmsson +354 858 0078 vv1412@outlook.com

For questions regarding the interpretation or application of this policy, contact the ESG Director of Hampiðjan Group.