VTT Whistleblower channel and whistleblower protection
1 Purpose, scope and responsibilities
The purpose of this guideline is to instruct VTT employees and the external parties mentioned in the guideline on
- what kinds of matters can be reported to the VTT Whistleblower channel
- how the channel is used
- how reports are processed
All VTT activities are guided by the legislation and strategy and as well as VTT’s values, ethical principles and commitment to responsible conduct. The Compliance function is assigned to support and ensure compliance with laws, regulations, VTT guidelines and ethical practices. A key part of our Compliance programme is the Code of Conduct, which compiles essential procedures and guidelines that are obeyed at VTT.
Do not hesitate to report violations or suspected violations of the Code of Conduct or the law so that we can address such issues. Misconduct or suspected misconduct should primarily be reported through the reporting channel, i.e. the Whistleblower channel. VTT’s Compliance Officer and Internal Auditor are together responsible for processing reports of suspected misconduct in accordance with section 5.
This guideline is in line with the provisions of the Directive of the European Parliament and of the Council on the protection of persons who report breaches of Union law (EU 2019/1937, the Whistleblower Directive) and the Act on the Protection of Persons who Report Breaches of European Union and National Law (1171/2022, so-called Whistleblower Act), which regulates the national implementation of the Directive. The Whistleblower Act entered into force on 1 January 2023.
2 What matters can be reported?
The purpose of the legislation is to improve the monitoring of Union law and policies and promote the reporting of suspected misconduct as well as the protection of whistleblowers. Any person who, in the course of their work, detects or suspects activities contrary to the public interest in specified areas of European Union or national law can report their observations safely and securely.
This guideline covers reports submitted to VTT’s internal Whistleblower channel. The Whistleblower channel is for reporting breaches of Union law detected in the course of one’s work concerning the following:
- public procurement
- financial services, products and markets
- prevention of money laundering and terrorist financing
- product safety and compliance
- road safety
- environmental protection
- radiation and nuclear safety
- food and feed safety, animal health and welfare
- public health
- consumer protection
- protection of privacy and personal data and the security of network and information systems
- EU and national competition rules
- EU or national grants and state aid rules
- EU expenses, revenue and resources
VTT’s Whistleblower channel can also be used to report other actions that violate internal guidelines and rules, excluding suspected misconduct related to employment relationships, occupational safety or research ethics. The reporting channel depends on the type of misconduct.
In matters related to employment relationships, you should primarily contact your line manager or the People Lead (formerly HR manager) in your business area. The VTT Whistleblower channel is not intended for reporting employment-related matters or issues.
In matters related to occupational safety (harassment, inappropriate behaviour, bullying, sexual harassment and discrimination) reports are submitted to Report misconduct channel.
In suspected cases of research misconduct, VTT follows the procedure in the Responsible Conduct of Research guideline by the Finnish National Board on Research Integrity TENK. Reports of suspected violations of good scientific practice or research misconduct are submitted directly to VTT senior management. Reports can be submitted with a separate form internally at VTT. Reports cannot be submitted anonymously.
3 Who can submit a report?
Any VTT employee can submit a report.
The VTT reporting channel is also available to non-employees for reporting suspected misconduct by VTT or VTT employees. In these reports, whistleblowers can be natural or legal persons.
In addition to VTT’s current employees, whistleblowers can include previous employees, jobseekers, trainees, VTT’s partners or suppliers and the personnel of subsidiaries.
4 Reporting channels
Reports of suspected misconduct should primarily be submitted to VTT’s Whistleblower channel. Under certain conditions, described in more detail in section 4.2, reports can also be submitted to the centralised reporting channel maintained by authorities.
4.1 VTT Whistleblower channel
The primary reporting channel is VTT’s Whistleblower channel, which is intended for reporting suspected misconduct related to VTT’s operations. VTT’s Whistleblower reporting channel is operated by Webropol and the related Case Management -tool.
All reports are documented in the Webropol reporting channel.
The internal reporting channel can also be used by parties outside VTT for reporting suspected misconduct by VTT or VTT personnel.
The reporting channel can be accessed via the Intranet and the VTT website. Reports can be submitted in Finnish or in English. At VTT, reports can also be submitted anonymously to the reporting channel.
4.2 Other reporting channels
The Office of the Chancellor of Justice is responsible for maintaining a centralised reporting channel in Finland. The Office of the Chancellor of Justice is also responsible for transferring reported issues to the competent authority for processing if necessary. Reports can be submitted to the reporting channel of the Chancellor of Justice if:
- an organisation does not have an internal reporting channel or the whistleblower has not been given an opportunity to submit a report via the internal reporting channel
- the whistleblower has a justified reason to believe that the internal report did not lead to necessary measures being taken for determining the accuracy of the report and for intervening in the misconduct if necessary within the time limit laid down in legislation
- the whistleblower has a justified reason to believe that certain misconduct cannot be effectively addressed on the basis of an internal report
- the whistleblower has a justified reason to believe that reporter is at risk of retaliation as a result of submitting a report
The external reporting channel of the Office of the Chancellor of Justice is available at https://oikeuskansleri.fi/en/how-to-make-a-report with more detailed instructions for making a report. The reporting channel of the Office of the Chancellor of Justice does not accept anonymous reports.
5 Processing of reports
Whistleblowers can submit reports of suspected misconduct observed at VTT by filling in an electronic Webropol form. The system issues a personal code for the whistleblower that they can use to log in to the Case Management system and communicate with the processors if necessary. The whistleblower has to save the code when submitting the report, as they will not be able to receive it afterward or reactivate it. The whistleblower can monitor the processing of their report by logging into the system with the code. Using the code enables communication with processors even if the whistleblower wishes to remain anonymous.
All reports are recorded in the Webropol Case Management system. Reports submitted through the Whistleblower channel can only be viewed and processed by the Compliance Officer and Internal Auditor. All actions taken to process a report are documented in the system.
The whistleblower will receive an acknowledgement of receipt within seven (7) days of submitting a report. If the whistleblower has submitted a report with name, the Compliance Officer/Internal Auditor will ensure that personal data and other identifying information are not revealed to the persons processing the case. If a report cannot be processed without the above-mentioned information, the whistleblower will be asked to give permission to disclose the information to the Compliance committee. All notifications are processed by the Compliance committee whose members are:
- VTT Compliance Officer
- VTT Internal Auditor
- VTT General Counsel
- VTT SVP of Human Resources
If investigating the matter requires contacting other persons, this can be done via Case Management without disclosing the whistleblower’s identity. The independent and impartial processing of reports is ensured by excluding disqualified persons.
The whistleblower will receive a statement and information on further actions resulting from the report and instructions for possible external reporting within three (3) months of receiving the report.
6 Processing of personal data
When investigating suspected misconduct at VTT, personal data is processed in accordance with current regulations applicable to the processing of personal data and according to VTT guidelines.
As a rule, all data collected on the basis of a report will be deleted within five years of receiving the report, unless otherwise required by law.
7 Whistleblower protection
A whistleblower’s employer or another organisation that supervises the whistleblower’s work or is otherwise in professional contact with the whistleblower may not take retaliatory action against the whistleblower due to reporting or bringing forth information about a violation.
Submitting a misconduct report will not have any negative consequences for the whistleblower if:
- the report has been submitted through the channels specified in this guideline
- the whistleblower sincerely suspects misconduct
- the whistleblower has a justified reason to believe that the reported matters fall within the scope of this guideline and the scope of the Whistleblower Act
The whistleblower will not suffer unjustified direct or indirect harm as a result of the report. Prohibited means of retaliation include threats of retaliation, attempts of retaliation, and preventing the submission of a report or attempting to do so. However, the prohibition of retaliation does not prevent the employer from making employment-related decisions that are not related to the report.
At the time of reporting, the whistleblower must have a justified reason to believe that reporting is necessary to reveal a violation. In this case, the whistleblower is not violating disclosure restrictions or other contractual obligations unless the information has been obtained or received via a criminal act.
However, unfounded reporting or intentionally submitting misinformation may lead to employment consequences, including termination of employment. An intentionally unfounded report may also cause liability for damages and criminal responsibility.