Whistleblowing policy
Written by Dino Hrgetić
Updated over a week ago


Favro AB and our affiliates (“Favro”) are committed to maintaining the highest standards of ethical behavior, honesty, and integrity. As part of this commitment, we encourage all employees to report any concerns or suspicions they have about any illegal or unethical behavior at the workplace. This policy outlines the process for reporting such concerns and ensures that employees who make such reports will be protected from retaliation.

We must all show the courage to raise concerns and to challenge actions, decisions, or behaviors that we believe to be wrong. We will not tolerate any retaliation or discrimination against anyone who raises or reports a concern in good faith, and we guarantee the highest possible protection for whistleblowers, those implicated and those contributing to the investigation of misconduct.

This policy applies to all employees of Favro, as well as contractors, suppliers, and anyone else working on our behalf.

What is whistleblowing

In this policy, whistleblowing means the reporting of suspected misconduct, illegal acts, or failure to act in relation to Favro.
The types of concerns that should be reported may include, but are not limited to, the following:

  • Danger to health or safety,

  • Fraud, theft, or embezzlement,

  • Discrimination, harassment, or bullying,

  • Failure to comply with any legal requirements or provisions of Favro internal policies, e.g. requirements on confidentiality,

  • Environmental violations,

  • Bribery or corruption,

  • Any other illegal or unethical behavior.

The aim of this policy is to encourage employees and others who have serious concerns about any aspect thereof to come forward and voice those concerns.

Who is a whistleblower

A whistleblower is a person who comes forward and shares their knowledge about any wrongdoing that they think is happening in the whole organization or in a specific department. A whistleblower could be an employee, contractor, or a supplier who becomes aware of any related activities.

To protect whistleblowers from losing their job or getting mistreated, this specific policy clearly states how to report such an incident.


Whistleblowing Policy is put in place to encourage employees and others to report any unethical or illegal activities that they may observe within Favro. That is why an important aspect is the ability to report anonymously. Favro ensures that the concerns raised by employees and others are communicated to the appropriate neutral parties without compromising whistleblowers’ confidentiality.

If an employee has a concern about any illegal or unethical behavior in the workplace, they should report it immediately using our independent reporting channel favro@walless.com. This inbox is monitored by our legal partners who are obliged to maintain the confidentiality and ensure that whistleblowers’ reports are forwarded to appropriate recipients.

Employees who report concerns will be protected against retaliation. Retaliation includes, but is not limited to, any adverse action taken against the employee, such as termination, demotion, suspension, or harassment. Any employee who retaliates against someone who has made a report will be subject to disciplinary action, which may include termination of employment relations.


We examine every report thoroughly and follow it up. Our investigation process is conducted with the most care and confidentiality, and reports will be processed and stored in a secure manner.

The investigation will be conducted in a fair and impartial manner, and all parties involved will be treated with respect and dignity. The investigation will be kept confidential to the extent possible, and only those who need to know will be informed of the details.

The findings from an investigation will be documented, with all attempts made to preserve confidential information. The whistleblower will be supplied with relevant reports, however, there may be circumstances where it may not be appropriate to supply certain information to the whistleblower. Reports will be handled confidentially when it is practical and appropriate in the circumstances. Each report will be assessed and may be the subject of an investigation. The objective of an investigation is to determine whether there is enough evidence to substantiate or refute the matters reported.

Favro may determine the most appropriate time to inform the individual who is the subject of the report about the investigation, before making any adverse findings against them. In some circumstances, informing the individual at an early stage of an investigation may compromise the effectiveness of the investigation, such as when there may be concerns that the individual may destroy information, or the disclosure needs to be referred to governmental regulators or the police.


We would like to inform you about the collection, processing, and use of personal data within the framework of this Whistleblowing Policy. If you provide your personal data via the whistleblowing channel, Favro will become the controller of your personal data for this purpose.


Management and investigation of whistleblowing reports.

Data subjects

Whistleblowers as defined herein.

Personal data

  • your name (if you choose to disclose your identity),

  • your contact details (if you provide them),

  • content of your report,

  • work-related context with Favro (if you provide such information),

  • names of persons and other personal data of the persons you mention in report (if applicable).

Please note that Favro may not process all the above data, and the scope of the processed data mostly depends on the information you choose to provide.

Legal grounds for processing

Such processing is necessary to comply with legal requirements (e.g. requirements on whistleblowing as mandatory in some countries where Favro is located) (Article 6(1) (c) of the GDPR) and for the legitimate interest of Favro to prevent and investigate violations described in this policy (Article 6(1)(f) of the GDPR).

If you do not provide the information required to comply with legal requirements, we may be unable to investigate the report.


It is important to mention that this Whistleblowing Policy involves a neutral party. A neutral party refers to a party that is not involved in the matter being reported and does not have any vested interest in the outcome of the investigation. Law firm WALLESS will take the position of a neutral party in this Whistleblowing Policy.

Your personal data will be disclosed to the representative of WALLESS (whistleblowing channel provider for Favro) responsible for management of the whistleblowing reports.

Furthermore, under specific set of circumstances, your personal data may be disclosed:

  • to police or government authorities in order to assist them in the performance of their duties;

  • to lawyers in order to obtain legal advice or representation with regard to whistleblowing provisions;

  • with the consent of the whistleblower.

Data retention

Personal data is stored for as long as required for the investigation of the report or as required by law. After that, this data is deleted in accordance with legal requirements.

You may find more information about your rights as a data subject and processing of employees’ personal data in the Favro Employee Privacy Policy.

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