Whistleblowing

About reporting

For United Bankers (UB) it is of importance that we are informed of actual or suspected misconduct that may arise within our operations. Therefore we welcome whistleblowing reports to our whistleblowing channel also from outside UB. The whistleblower is protected by the Act on whistleblower protection (Law on the protection of persons who report breaches of Union law and national law, 1171/2022), later “the Act”, when certain conditions (see below) are met. Kindly make sure that you use this channel solely for reporting serious breaches.

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What topics can be reported?

You can report actual or suspected misconduct or breach of regulation or policies that may have taken place at UB. You may also report human rights related risks or breaches of human rights that have to do with UB’s activity or investments. Please note that HR-related topics are not within the scope of the Act and thus a person reporting such topics is not granted the protection under the Act. However we still welcome reports to this channel regarding HR-topics.

Processing of the reports

Our whistleblowing channel is built in a way that no information that could connect the report to the whistleblower is gathered. This enables the whistleblower to make an anonymous report upon wish. Should the whistleblower wish to make an anonymous report, the whistleblower receives a link and a PIN code with which it is possible to discuss anonymously with the person processing the report. Please note that even in situations where you file an anonymous report you may be recognized indirectly in some situations because of the context or circumstances.

Reports are processed impartially and independently by persons specifically appointed to the task. In addition UB may appoint experts to examine the authenticity of the alleged misconduct or breach as well as other persons to investigate a specific case together.

UB will examine reports and take appropriate measures. A whistleblower who provided contact details will receive a receipt and within 3 months from the receipt information about the actions taken.

Requirements of EU’s General Data Protection Regulation (EU) 2016/679, The Act on the Protection of Privacy in Working Life (759/2004) and Data Protection Act (1050/2018) are complied with when processing personal data.

Conditions for protecting the whistleblower under the Act on whistleblower protection

Conditions set out in the Act on whistleblower protection:

• Breach took place in an area that is within the scope of the Act (such as financial services, products and markets, prevention of money laundering and terrorist financing, consumer protection) and the breach was an act or failure to act that is punishable and may result in an administrative sanction of a punitive nature, or which may gravely endanger the achievement of the general objectives of the legislation.

• The whistleblower reports a breach discovered in the course of their work (work context requirement).

• At the time of filing a report, the whistleblower has reasonable grounds to believe that the information about the breach is accurate and the information about the breach falls within the scope of the Act.

• The whistleblower files the report primarily to the channel provided by the company unless reporting to an official is obliged by law.

• The whistleblower only reports to an official instead of the company in situations where the whistleblower is not given access to the channel provided by the company itself, the whistleblower has reasonable grounds to believe that no action has been taken within the timeline set out in the Act or that the breach cannot be effectively addressed at the company itself, or the whistleblower has reasonable grounds to believe that they are at risk of retaliation.

• The whistleblower who makes the information of the breach public is granted the protection under the Act only when the whistleblower has filed a report to the official but the whistleblower has reasonable grounds to believe that the official has not begun to investigate the report within the timeline set out in the Act or the whistleblower has reasonable grounds to believe that the breach may endanger public interest directly and obviously, filing a report to the official may bring about danger of retaliation or the official has participated in the breach or it is otherwise likely that the official will not take due measures as a result of the report because of the specific circumstances relating to the matter.

Reporting to the centralised external reporting channel of the Office of the Chancellor of Justice

You may report a misconduct that took place within the operations of UB to the centralised external reporting channel of the Office of the Chancellor of Justice if the breach falls within the scope of the Act and applicable conditions listed above are met. Kindly note that one condition for the protection under the Act is that a report about a breach that took place within the operations of a company is made primarily to the channel provided by that company itself. Read more about reporting to the Office of the Chancellor of Justice and about the conditions for protection at: Chancellor of Justice – How to make a report? »

 

How to file a report? Instructions for whistleblowers »

 

File a report »