In the whistleblower system, you can report serious matters such as, e.g., bribery, extortion, embezzlement, theft, accounting irregularities, etc.
Matters such as bullying, dissatisfaction with wages, violations of the alcohol policy, etc., should not be reported here. They should instead be reported through the normal channels.
To ensure your anonymity, you must do the following:
When you send the report, you have the option to choose whether you remain available for further inquiries by opening a secure post box.
We recommend that you make yourself available because we may not be able to finalise the case without further information from you.
When you create a post box, you will be given a case number, and you will choose a password. You will use the case number and password to log in to the post box in order to see if you have received any questions.
Regardless of whether or not you remain anonymous or you write your name, we ask you to open a post box. This makes it safer and easier for us to communicate.
All communication with us is anonymous if you wish it to be.
The Whistle-Blower policy underpins our obligations as a Model Company, and the management of the ALTATERRA Group wishes to encourage an open dialogue on all issues related to illegal business methods, non-compliance with our policies and other issues that may be considered illegal.
The purpose of the whistle-blower system is to ensure that issues or behaviour deriving from employees in ALTATERRA entities, or others with a relation to companies within the ALTATERRA Group, can easily and securely be reported to an external and impartial party under observation of the General Data Protection Regulation. Furthermore, we want to ensure that this can be done at any time and that nobody will be subject to harassment or other discrimination when using the whistle-blower system in good faith.
All employees, and others with a relation to entities within the ALTATERRA Group (including members of ALTATERRA Management Team and the Board of Directors) are covered by the whistle-blower system and can report such matters to the system for investigation.
The whistle-blower system can be used solely to report criminal offences that may affect the company or that may have an impact on the life or well-being of an individual. Examples are:
The whistle-blower system cannot be used to report minor offences such as dissatisfaction with salary level, infringements of guidelines on smoking and alcohol, workplace bullying, cooperation difficulties or other HR-related personnel issues. You are recommended to discuss issues that do not concern illegal aspects with the person(s) who in your opinion do(es) not act appropriately before you bring an issue to a higher level. Should you decide to escalate an issue, you should report it to your immediate superior, HR or a relevant person of trust, for instance a trade union safety officer.
The data controller of the whistle-blower system is the HR Manager Ivett Kovacs at ALTATERRA Kft.
You can make a report by going here
What information will be registered?
The system can only be used to report on significant matters such as, e.g., financial crimes, significant work safety violations, significant violations of environmental regulations, and on environmental pollution, physical violence, sexual assaults, etc.
If reports on less significant matters, such as, e.g., dissatisfaction with wages, difficulties with cooperation and violations of smoking and alcohol policies are received, this information will be deleted immediately.
By “organisation” is referred to the organisation that receives the report.
The registration of reports takes place anonymously in the system. The only thing that is registered is the report itself. There is no log made as to the IP address or machine ID of the computer on which the report is made.
If you realise that you have provided incomplete or incorrect information, just make a new report in the system in which you refer to the previous report and describe what should be corrected.
If you, in connection with the creation of a report, have decided to create a secure post box, you can make the correction by logging in to the system using your case number and the password you had created.
The information registered in the system is generally not transferred to a third party outside of the organisation. However, in the following circumstances, the information may be transferred onward:
If you provide your personal information, be aware that the organisation can use your personal information when investigating the case, and also during any subsequent lawsuit.
The organisation guarantees that your personal data protection rights will be respected without limitations and will only be used as described above.
The organisation will not share your personal information with third parties outside of the organisation except for the cases as described above in the section ”Transfer of registered information”.
Registered data may only be retained for as long as there is a need for it.
When there no longer is a need for retaining the registered information, the information is deleted.
The reporting system is hosted by Got Ethics A/S, an independent party guaranteeing the system’s security and anonymity.
Got Ethics A/S has taken the necessary technical and organisational measures to prevent personal data from being accidentally or unlawfully destroyed, lost or damaged and to prevent any unauthorised disclosure or misuse of the personal data. The processing of personal data is subject to strict controls and procedures and is in compliance with good practices in the field.
All data is transmitted and stored encrypted. No unencrypted information is sent over the open Internet.
If a report is made from a computer on the organisation’s network, there is a risk that the visited webpages will be logged in the browser’s history and/or the organisation’s log. This risk can be eliminated by submitting the report from a computer which is not connected to the organisation’s network.
If you upload documents, you should be aware that the documents can contain metadata which can compromise your identity. Therefore, you should ensure that any identifying metadata is removed from a document before it is uploaded.
It is optional to make either an anonymous report or a report containing personal data. If a reporter chooses not to remain anonymous, the reporter’s identity will be known to the persons that handle the case. In this case the reporter risks being called as a witness in any lawsuit, and the reporter’s anonymity thus can be lost.
Be aware that if you choose to give further information when submitting the report from which you can directly or indirectly be identified, the organization will also process this information when handling the case. This also apply if you have chosen to remain anonymous.
What is the legal basis for the organisation’s processing of information in the system?
The legal basis for the processing of your information is as follows:
According to the European Data Protection Regulation you have a number of rights. If you want to exercise these rights, you must contact the organisation.
You can read more about your rights here
The organisation is data controller for the processing of the personal data that you report and can be contacted through the ordinary communication channels. Likewise, the organisation’s data protection officer can be contacted through the ordinary communication channels (if they have appointed a data protection officer) if you have questions about the processing of the information.
If you want to complaint about the processing of your personal data, you are entitled to submit a complaint to the competent supervisory authority.
You can download a list of the European supervisory authorities here
1. MALOM KÖZ