Whistleblower – do you know something we should know?

We want to recognise and react to non-compliance at an early stage. Therefore, within the LKAB Group, we have various opportunities for so-called whistleblowers, who want to report suspected abuse and irregularities.

Good business ethics are essential for us to operate successfully and deliver our strategy. Our Code of Conduct and our core values form the basis and show the way for how we should act in different situations. We want to identify and respond to non-compliance at an early stage. The ability to report suspected misconduct and serious irregularities is therefore important. Within the LKAB Group there are several reporting options, all of which comply with applicable national and international regulations.

If you suspect that a company within the LKAB Group or someone acting on behalf of such a company is acting in violation of applicable legislation, our policies or internal procedures, you have the opportunity to report it. To enable reporting, we have established two different types of reporting channels:

1. Local reporting channel

Each LKAB Group company with 50 or more employees has established a local reporting channel. By reporting through such a reporting channel, you receive special protection under the Whistleblower Act (SFS 2021:890).

2. LKAB's Group-wide reporting channel

In addition to the local reporting channels, LKAB has established a Group-wide reporting channel for all companies in the LKAB Group. If you do not want to or cannot report to a local reporting channel, you can choose to report to our group-wide reporting channel, LKAB Group.

Frequently asked questions

Information about an irregularities in a work-related context that there is a public interest* in it coming to light or that constitutes a suspected violation of certain legislation**
Only group companies with 50 or more employees have such a reporting channel, in accordance with the Whistleblower Act.
The following categories of persons may report if, at the time of reporting, they have reasonable grounds to believe that the information is true:
The following categories of persons may report if, at the time of reporting, they have reasonable grounds to believe that the information is true:
·         employee
·         Trainees
·         Volunteers
·         Self employed
·         persons who otherwise perform work under the control and direction of the company;
·         persons who are members of the administrative, management or supervisory bodies of the company;
·         shareholders who are active in the company.

*Examples of things that are of public interest are serious violations of LKAB’s Code of Conduct, violations or other violations of the law.
**For example, offences in public procurement, financial services, products and markets, terrorist financing, product safety, environmental protection, transport security, public health, network and information security, competition rules, protection of privacy and personal data, corporate tax rules, prevention of money laundering, product compliance, acts affecting the EU’s financial interests.
Information that someone within the group in an executive position, e.g.  CEO, members of the management team, persons responsible for large purchases or other business-critical areas, committed a serious breach of our Code of Conduct or the law (“serious misconduct”). For example:

·         LKAB’s Code of Conduct
·         accounting, internal accounting control and auditing
·         bribery, corruption, fraud and other financial improprieties
·         work environment violations that endanger life and health
·         very serious forms of discrimination or harassment (e.g. sexual harassment)
·         serious environmental crimes
At the time of reporting, the reporter must have reasonable grounds to believe that the information is true.
If the misconduct relates solely to one’s own working or employment conditions, it is generally not considered to be in the public interest, unless it is something that is completely unacceptable from a broader societal perspective.

Questions relating to your own employment relationships should instead be reported via LKAB’s normal channels of communication, i.e. to your manager, their manager or HR. You can also contact your trade union representative.

If a report received is not deemed to constitute a whistleblower case under the Whistleblower Act, or a serious irregularity according to this document, the reporter will be notified and the case will be closed.
Examples of information that should appear in your report are:
•       Date, time, and location of the event
•       A description of what has happened, and your possible part in the reported incident
•       Names and functions of any persons concerned
•       Witnesses, if any
•       Other useful information for us to understand the incident and process your report

To make it easier for us to investigate your report, we encourage you to be as specific as possible. If the information you have provided is too general, you may be asked to provide additional information.
A report can be submitted completely anonymously. Normally, the subsequent investigation and other handling of the report is favored if it is possible to have contact with the reporter during the investigation. It can therefore be an advantage if the reporter chooses to provide name and contact details in connection with the reporting, or if the person wants to maintain anonymous, that the reporter goes into the case that was created at the time of the report in SpeakUp and checks whether additional information has been requested.
A person who has made a report in good faith is protected from retaliation. Retaliation is any direct or indirect action taken or omitted as a result of a person’s reporting, such as adverse salary action, withdrawal of benefits or failure to promote. Protection against retaliation also applies to people who help the person make a report, such as elected officials, safety representatives, and people with some connection to the whistleblower, such as relatives and colleagues.

The protection against reprisals under the Whistleblower Act applies provided that
•       The reporter had reasonable grounds to believe that the information reported was true at the time of the report;
•       the reported wrongdoing is in the business in which the reporter works, will work or has worked, or in the activities with which the reporter is otherwise involved through his or her work (“work-related context”); and
•       the report was made through a local reporting channel or external channels. If there are no local reporting channels, the protection also applies to reporting in LKAB’s Group-wide reporting channel.

If you report through LKAB’s Group-wide reporting channel, you will only be covered by the protection against reprisals under the Whistleblower Act if the Group company where you are an employee or otherwise related does not have a local reporting channel. However, LKAB is committed to protecting you from reprisals in other cases when you report through LKAB’s Group-wide reporting channel, provided that the report is made in good faith and in accordance with the provisions of this document.
Once you have submitted a report, you will receive a case number that you can use to log in via app, phone or web and get updates on the case. Sometimes there may also be a need to ask supplementary questions about the case, where you can be of help with important information.

Your report will be treated confidentially and will be received by a whistleblower manager. A whistleblower manager is a person appointed by the company and who is authorized to independently and independently handle reports received. There are always at least two designated whistleblower managers. In the event of a conflict of interest regarding information provided in a submitted report and a whistleblower manager, the whistleblower manager is obliged to immediately notify LKAB’s General Counsel. The relevant whistleblower manager’s access to the case is removed and the General Counsel decides how to handle the report received.
A person who wishes to report irregularities that there is a public interest in accordance with the Whistleblower Act has the possibility, instead of choosing to report in the internal reporting channel, to report to the authority appointed by the Government. For more information about which authority has been appointed regarding which types of reported misconduct and how to report to them, read this document (available in Swedish only).

Under certain conditions, the Whistleblower Act also provides the opportunity to report publicly about irregularities that there is a public interest and of suspected violations of certain legislation. Reporting publicly means that the reporter can go to the media, e.g. a newspaper with a publishing license, to publish the information. The right to disclose information to the media for the purpose of publishing it for publication is also constitutionally protected. There is also a constitutional right to collect data for the purpose of providing the information for publication through publication in certain media.

However, the right to report publicly and to otherwise disclose information to the media for publication may be limited by, among other things, an agreed duty of confidentiality (confidentiality undertaking) and general principles regarding the duty of loyalty in employment relationships in the private labour market. In order to be covered by the protection under the Whistleblower Act in public reporting, a number of conditions must also apply. A person who is considering reporting publicly or otherwise disclosing information to the media is therefore recommended to first seek legal or trade union advice.