Whistleblowing policy

Owner/approver: Group Director HR

Valid from: 2021-04-29

Purpose

Lerøy Seafood Group (Lerøy) has a goal to be the leading and most profitable global supplier of sustainable high-quality seafood. In order to achieve this goal, it is essential to ensure that Lerøy's business results never take priority over compliance with prevailing acts and regulations and the Group’s Code of Conduct. Lerøy’s Code of Conduct reflects the Group’s fundamental values and guides the employees as to which principles to follow. 

Lerøy’s principal goals represent an organisational culture with a positive and constructive climate for freedom of speech. The whistleblowing regulations shall allow employees or externals to speak out and criticise without the risk of any kind of punishment or negative reaction.

All employees and externals are encouraged to report censurable conditions as this can help rectify such situations. All employees are obliged to report any criminal acts and situations involving a risk to life and health.

Whistleblowing

Whistleblowing is defined as reporting censurable conditions to a person with the authority to do something about it. Employees or externals who are willing to whistleblow represent an important resource for Lerøy. 

The term “censurable conditions” is defined as situations that violate rules of law, the Group's Code of Conduct or ethical standards, for example situations that may represent:

• a risk to life or health
• a risk to the climate or environment
• corruption or other economic crime
• abuse of authority
• unsatisfactory working environment (e.g., HSE, bullying, discrimination)
• breach of personal data privacy (GDPR)

Statements relating to issues that only apply to the employee’s own working conditions, such as professional disagreements and terms, are not defined as whistleblowing.

Whistleblowing channels

People can whistleblow orally or in writing, with their full name or anonymously. Lerøy have both an external whistleblowing channel for persons outside the company and an internal whistle blowing channel for employees  The whistleblowing report should contain relevant information, including persons involved, any witnesses and relevant evidence.

Employees who reports  reports orally, shall as a main rule contact their immediate superior. If this feels difficult, the employee can contact their immediate superior’s manager, the local HR Department or the local employee representative/safety representative. Oral whistleblowing reports are registered in Lerøy's digital whistleblowing channel by the person who receives the report.

Lerøy has established a digital channel for whistleblowing, which allows persons to remain anonymous. Whistleblowers who choose to be anonymous should note that they will not receive feedback regarding follow-up and management of the report.

Employees and externals are encouraged to whistleblow with their full name, as anonymous whistleblowing may complicate management of the case and prevent clarification of and reaction to censurable conditions. Normally, whistleblowing with full name will help improve proceedings and provide a better result for all parties involved.

Follow-up of whistleblowing and protection against retaliation

Initially, whistleblowing reports received via the digital channels will be processed by an independent third party, who will evaluate whether the report represents censurable conditions. The third party then makes a recommendation for further processing by Lerøy’s whistleblowing committee.

The whistleblowing committee covers all Group companies, in order to coordinate processing and implementation of action in the event of nonconformances. The procedure for investigations will depend on the nature and severity of the case, and is flexible to cover the wide diversity of possible whistleblowing cases. If necessary, external resources are contracted.

The whistleblower shall receive feedback within 14 days to confirm that the report has been received and to provide information on proceedings.

All parties involved in a whistleblowing case shall be protected. Retaliation against employees or externals who whistleblow is prohibited. Any person who feels that they have been subject to retaliation after whistleblowing must report this in Lerøy's digital whistleblowing channel.

Confidentiality

The whistleblower’s identity and all information relating to a whistleblowing report are treated as confidential information throughout the process. It is important to note that anonymity cannot be guaranteed for whistleblowers and others if the case results in legal proceedings. 

Case management will be carried out in accordance with the prevailing legislation covering personal data and privacy.

Reports

Lerøy’s whistleblowing committee shall issue quarterly reports on the status of whistleblowing cases to the Group management and Board of Directors.

Valid for

Applies to all employees and contract labour at Lerøy.

Framework and principles

Chapter 2A of the Norwegian Working Environment Act

Lerøy's Code of Conduct and whistleblowing poster

Roles and responsibilities

• All employees at Lerøy are responsible or complying with the policy and for contributing towards creating and sustaining a proper and safe working environment.
• The top management in each company is responsible for ensuring that the company has personnel with the competencies required to ensure compliance with local regulations.
• Managers shall provide guidance for employees who wish to whistleblow.

Policy ownership and implementation

• The CHRO at Lerøy Seafood Group is the owner of this document, and is responsible for
• The policy has been approved by the Corporate Management Group, presented to the Audit Committee and approved by  the Board of Directors
• The CEO of Lerøy Seafood Group has overall responsibility for the policy.