Guidelines

Background

Whistleblowing involves drawing attention to misconduct, and the concept has come to be used for alerts to the media as well as when internal issues are identified.

Konserthuset Stockholm has a whistleblowing system where employees and other concerned parties can anonymously report misconduct within the organization. The whistleblowing system is hosted by an external entity to prevent the disclosure of the identity of the informants. Information about the channel is available on the intranet and external website. It is not possible to identify the person behind a report, and therefore, it is not possible to verify if the person is employed within Konserthuset Stockholm. All reported cases will be considered.

Purpose
The system aims to clarify everyone's responsibility in collectively identifying problems and areas where we, as an organization or our employees, are not in compliance with current laws or do not fully adhere to our guidelines. The system also serves as a reminder of the organization's responsibility to specify the rules in effect and what is expected of employees. Overall, the whistleblowing system is intended to strengthen a culture where issues are addressed and discussed.

Our strong hope is that all employees feel there is a high enough ceiling to openly discuss problems. However, the option to report anonymously is a way to demonstrate that no one should fear consequences for reporting misconduct.

The whistleblowing function is a complement and should not be seen as a replacement for an open dialogue climate. Normally, as an employee, you would turn to your immediate supervisor or someone in the leadership you trust.

Konserthuset Stockholm enforces a total prohibition on retaliation. This means that we have zero tolerance for actions aimed at punishing anyone who reports misconduct – whether actual or perceived – as long as the reporting was made in good faith. However, deliberate defamation or spreading of rumors is not tolerated.

The channel is intended for serious violations, such as violations of Swedish or EU legislation, as well as cases that can be considered to be of public interest. It is such cases that will be processed in the defined handling process of the whistleblowing system. Other cases will be referred to the appropriate party.

About the System
For the system to be credible, it is important to ensure transparency and clarity regarding how we protect the user's privacy. It is also important to assist informants in providing as much relevant information as possible. Some aspects that Konserthuset Stockholm has specially considered include:

• Independent case handling. Cases deemed to be whistleblowing cases according to the legal definition are investigated by a specially designated trust group or by an external independent attorney.
• Information for users. As an informant, you should know how you are technically protected and what you need to be aware of to avoid disclosing too much information. This can involve user data in attachments, risks of reporting from the workplace's network, or the risk of revealing oneself through one's expressions.
• Data storage. We have chosen a provider with servers located in Sweden. Handled cases are deleted from the system so that information is not retained longer than necessary.
• Information management. No sensitive information should be sent via email; instead, personal login is always required to access and work with case information.
• Reporting quality. Clear questionnaires help informants provide comprehensive information to facilitate case investigations. As a complement, there is the option to correspond anonymously with the informant.
• Accessibility. Mobile adaptation of the reporting page is essential, as communication increasingly occurs via mobile devices. An additional advantage is that mobile devices often operate outside the workplace's network and thus offer a privacy-friendly alternative to the work computer during working hours. The option to submit cases by phone is also available.

About Handling
Cases are handled by a specially designated trust group or an external independent attorney. Investigation and any recommendation for action or further handling are presented to Konserthuset Stockholm's management team by Stefan Forsberg Executive and Artistic Director or Anne Rajala Human Resources.

If Konserthuset Stockholm‘s management team should be disqualified or if there are other reasons why the above process cannot ensure independence in handling, the case will be investigated by an external independent attorney who reports to Board of directors.

Cases that fall outside the system's scope will be dismissed from the whistleblowing process.

Persons identified in a case are informed of ongoing investigation as soon as it is feasible considering the investigative work. However, the identity of the informant is not disclosed, even if it is known to the investigator.

After handling, the case is deleted from the database. If the case requires further investigation, necessary information is saved outside the database. The information is destroyed or anonymized as soon as it is feasible considering the investigation.

If an informant chooses to be open about their identity, their identity will still be exclusively made available to the group designated to handle whistleblowing cases. The exception is if the case results in a criminal investigation, in which case the informant may be called as a witness.

Evaluations and Improvements
To ensure that the whistleblowing system serves its purpose, regular evaluations are conducted to assess how the channel is used, whether relevant individuals are aware of the channel, whether the types of cases align with the system's purpose, and whether the handling procedures function as intended.

Responsible for the Function
Stefan Forsberg
Executive and Artistic Director
+ 46 8 786 02 00
stefan.forsberg@konserthuset.se

Anne Rajala
Human Resources
+46 8 786 02 45
anne.rajala@konserthuset.se