Whistleblowing policy

Who may submit a report through the whistleblowing channel?

Do you have knowledge of a wrongdoing conducted in relation to TreeToTextile’s, org. nr. 556989-2648 (”TreeToTextile”) business? Could the wrongdoing be considered of public interest? If so, you may use our internal reporting channel for making this wrongdoing known. The internal reporting channel is available to;

– workers/employees,

– job applicants and others making enquiries about employment,

– volunteers and applicants for volunteer positions

– trainees and applicants for trainee positions

– in-house consultants that work for, or that are available to perform work for TreeToTextile,

– self-employed persons performing work for, or that are available to perform work for TreeToTextile,

– shareholders and persons belonging to the administrative, management or supervisory body of TreeToTextile, including non-executive members, 

– any persons working under the supervision and direction of contractors, subcontractors and suppliers,

– persons who have previously belonged to one of the categories above and has obtained their knowledge of the wrongdoing through their position.

Other avenues for raising concerns

TreeToTextile strives to offer a safe working environment where each and every one should feel comfortable voicing their opinion. If you are comfortable doing so, you can always raise any concerns with your closest superior, HR or someone in management. HR can be reached at linda.saegebrecht@treetotextile.com, 0732-455405. If the information you want to bring forward is not such that it would be considered of public interest, this is the avenue you should use. Such information may include instances of salary dissatisfaction or cooperation difficulties with a co-worker.

Internal reporting channel

  1. Reporting through the internal channel is limited to reporting on wrongdoings that may reasonably be considered of public interest. It can for example be information on financial crimes, corruption, breaches of working environment codes, or instances of discrimination or harassment. If you are unsure if the information you want to report would be of public interest, we encourage you to report anyway.
  2. You can submit your report in written format, orally or through the means of a physical meeting. When you choose to submit your report orally or through the means of a physical meeting, the conversation will normally be recorded. However, recording will only take place if you consent. The information you choose to submit will always be documented. When you submit a report through the internal channel, your identity will always be protected by confidentiality. In order to enable investigation of your report, you are always encouraged to include your contact details in the report.
  3. To report on a wrongdoing orally, or through the means of a physical meeting, please contact Peter Lexenberg at Wistrand law firm at phone number 08-50 72 00 72.
  4. To report a wrongdoing in writing, please send a letter to Peter Lexenberg, Wistrand law firm, PO Box 7543, 103 93 Stockholm.
  5. You have a right to confirmation of receipt of your report has been received within seven days after submitting it, unless you have declined such confirmation. Within three months of submitting your report you will receive information on the follow-up of your report. The documentation of your report will be kept as long as necessary, however no longer than two years after the follow-up of your report has been concluded.

Protection of whistleblowers

  1. Whistleblowers who submit a report through the internal reporting channel, are protected from retaliation as a result of their report. Retaliation may include, for example, suspension, lay-off, dismissal, demotion or withholding of promotion, transfer of duties, change of location of place of work, reduction in wage, change in working hours or a negative performance assessment or employment reference. An instance of retaliation may in itself be a wrongdoing that could be subject to a report through the internal whistleblowing channel.
  2. If you are subject to retaliation, and your report falls within the scope of the Swedish Whistleblowing Act (2021:890), you may be entitled to damages.

External reporting channels

In addition to the internal channel described above, you have a right to report wrongdoings through external reporting channels by contacting the relevant authority. A list of the relevant authorities can be found in the annex to Ordinance (2018:219) with supplementary provisions to the General Data Protection Regulation.

Personal data in the whistleblowing channel

  1. TreeToTextile is the controller of personal data processed through the internal whistleblowing channel, for example when reports are received, stored, investigated or deleted.
  2. If you have any questions regarding our personal data processing, please contact us through:

    Email: linda.saegebrecht@treetotextile.com Phone: 073-245 54 05
  1. Personal data will be processed in the whistleblowing channel based on Article 6(1)(e) GDPR (public interest) and the purpose of the processing is to enable wrongdoing related to TreeToTextile’s business.
  2. TreeToTextile may process personal data relating to criminal convictions and offences. Such processing is based on Ordinance (2018:219) with supplementary provisions to the General Data Protection Regulation and the Swedish Data Protection Agency’s (IMY) provisions DIFS 2018:2.
  1. The processing of sensitive data is based on Article 9(1)(g) GDPR.
  2. The personal data processed through the internal whistleblowing channel is mainly processed by TreeToTextile and Wistrand Law firm. If a report submitted through the system concerns a crime, the information may be handed over to the Police Agency or other relevant authority. 
  3. TreeToTextile does not transfer data outside of the EU/EEA. All personal data is stored on servers in the EU.
  4. The personal data processed through the internal whistleblowing channel will be processed for as long as necessary, although no longer than two years after the conclusion of the follow-up of your report.
  1. According to the GDPR you have a right to request access to and rectification or erasure of personal data as well as restriction of processing. You also have a right to object to processing as well as the right to data portability. Please note that, due to the context in which this personal data is processed, these rights may be limited due to the information being covered by confidentiality. 
  2. If you are employed with TreeToTextile and you would like further information on our processing of personal data in general, please see documentation on GDPR in SharePoint.
  3. If you are dissatisfied with our processing you may lodge a complaint with IMY. 
  4. Personal data is primarily collected from the reporting person. However, personal data may also be collected from other sources during the course of the investigation.