Whistleblowing policy


Do you have something you want to tell? We want to listen!

We maintain a healthy and open culture, where every employee has a responsibility to comply with applicable regulations and act ethically. We can solve many situations by talking to each other immediately when they arise. Sometimes things can happen that require a completely different handling.


Regardless, it is important to us that problems or more serious issues come to light so that we as an organization have the opportunity to act. In more serious cases such as various types of misconduct, or where there is danger to health and life, it is important that it comes to the surface in good time.


In this work, you as an employee or partner are a key factor. That is why we offer you the opportunity to blow the whistle to an external and independent adviser, with the option of being completely anonymous.


The following information describes the whistleblower process in a little more detail. For a more detailed and comprehensive description, see our full whistleblower policy.


Whistle blowing

Sometimes, based on what you need to say, it is not appropriate to raise the issue via the usual route in our organization. Then we offer you an opportunity to use a safe whistleblower function. This is an important safety valve for both us and for you as an employee. That is precisely why we use Trumpet, a whistleblower function where you can anonymously and confidentially report wrongdoing.


What can be reported?

There are restrictions in law on what may be handled in a whistleblower function. Therefore, through the whistleblower function, you may only report matters that constitute misconduct that there is a public interest in their disclosure (or violations of certain other legislation) that you have become aware of in your work with us. Our whistleblower channel should only be used to report misconduct within our own organization. General dissatisfaction with the way the business is conducted, leadership, salary or other personnel matters are not, as a starting point, misconduct that should be reported through a whistleblower function. Misconduct in which there is a public interest in coming to light is typically misconduct that affects the public to a greater extent, such as financial crime, environmental crimes and abuses that cause imminent danger to people's lives and health. If you feel unsure, you can, for example, consult a trade union representative.


A report via the whistleblower function Trumpet must be based on concrete suspicions. You do not need to have proof of your suspicion, but no accusation may be made with malicious intent or with knowledge that the accusation is false. False or malicious allegations are a serious breach of the employment contract. Reports must also not be based solely on rumors or hearsay. Read more in our whistleblower policy.


Who can make a report?

A whistle-blowing report can be submitted by anyone who in any way represents our organization or is professionally active in it. This includes board members, shareholders working in the business, all employees (permanent, probationary, fixed-term, full-time and part-time), consultants, interns, volunteers and contracted staff (staff).


This is how case management works

Trumpet is an external whistleblower function that gives you a secure process where you as a whistleblower can be completely anonymous. If you do not print your name in the report yourself, it is not possible to see who left the case in the function. Trumpet is developed based on the highest standards regarding confidentiality and security.


All matters are received by independent external handlers with solid experience in assessing, investigating and helping organizations deal with various types of irregularities. You can find more information about Trumpet here.


Trumpet meets the requirements of the EU's data protection regulation (GDPR) and the Swedish whistleblower law (law on protection for people who report wrongdoing).


The process, step by step:

By reporting in Trumpet, you can ensure that you are completely anonymous – no one knows who you are reporting, unless you choose to be open about your identity.

When you report an incident in the function, an encrypted case is created in the whistleblower system for which you receive a unique encryption key.

It is always an external independent expert – case manager in the Trumpet whistleblower function – who receives your case and makes the first assessment. Only you and your manager can access your report using your encryption keys.

To facilitate the process, you can actively make a choice to be open with your identity towards the independent administrator - but not towards our organisation. In this way, you and your manager can have an efficient and secure dialogue - no one else finds out who you are. There is also an opportunity for you to also choose to be open with your identity towards our organization.

After your caseworker has made their assessment, a recommendation is made to our organization's whistleblower committee. If someone on the committee is affected by your report, this is excluded by the administrator before the committee is given access to the report and the administrator's recommendations. Who is part of our whistleblower committee appears below. The Whistleblower Committee, in turn, decides how the matter should be taken forward and what measures should be taken. You can read how the committee works and who is included in our whistleblower policy .

Officers communicate the status of the case and the committee's decision to you through the secure encrypted login to Trumpet. It is therefore important that you save the encryption key in a suitable way.


How to report

You go to a web page in the whistleblower function Trumpet and choose there whether you want to make your report via a web form, telephone or letter. Registration can be made 24 hours a day, every day of the week. A notification through Trumpet is always handled with maintained anonymity and with the highest confidentiality. If you want to exclude anyone from being able to track your activity, you should choose a private computer or mobile phone and access the service from a network you trust, such as your home network.


  • You start your registration in the whistleblower function Trumpet by entering the address https://midway.trumpet-whistleblowing.eu/ on any device (computer, tablet or mobile phone) to get to the whistleblower page.


In Trumpet's system, you get clear guidance through the entire process. Answers to the most common questions can be found at each step.


If you choose to submit your report by phone or letter, it is important that you provide some form of contact information so that the case handlers can give you your login details to the case page in Trumpet. It is on the case page that the case handlers will provide feedback on how the case is progressing. If you want to remain anonymous even to Trumpet, it is important that you carefully consider which contact details you provide.


You can also submit your application through a physical meeting. If you want to request a physical meeting, contact Trumpet via the web form, phone or letter. If you wish to report through a physical meeting, anonymity cannot be promised, and you should be aware that the person you may meet may be directly employed by us.