This information is written as an attachment to the Agreement and contains information on the whistleblowing policy (“WP”) that we (The Whistle Compliance Solutions AB / Visslan) may provide.
If you have found this page via instructions in the WP that we have provided, you have either agreed to this document via the Agreement, or in other communications with us received this information and terms and thereby agreed to them. If you are unsure of your eligibility to use our WP, please contact us.
The WP is written according to the Swedish whistleblowing law (SFS 2021:890) and/or the Directive (EU) 2019/1937 of the European Parliament, however, we do not take responsibility for its compliance/non-compliance with the legal requirements applicable to your organisation.
The WP is constructed in a way to allow you to easily adapt it to your company in accordance with the Swedish whistleblowing law, with the use of our whistleblowing platform, Visslan.
Be aware that adopting the WP “as is” does in no way mean that you are complying with the abovementioned laws. Also, note that the WP needs to be adjusted according to your internal policies and/or procedures.
Enabling reporting of non-whistleblowing cases
As formulated in the WP, you could choose to open your Service (the Visslan software) to receive reports that are not within the legal definition of “whistleblowing cases”, and hence not covered by legislation or protection for the whistleblower. It is important to note that by doing this, you are responsible for any GDPR or data processing-related consequences, such as processing personal data without legal rights to do so. In this case, we recommend you to involve your data protection officer.
Hence, we do not take any responsibility for such adaptations of the policy (such as enabling reporting of non-whistleblowing cases), even where we have guided for how it could be done, and it is eventually up to you to comply with any problems, contradictions or such that can appear while adopting the policy.
The WP is not to consider legal advice in any way. We do not recommend you to implement the WP “as is” and cannot give legal advice if you have adapted the WP according to the different options in the WP or in any other way.
Use of the WP
You may only use the policy in connection with our Services, i.e. the Visslan software. If the Subscription as described in the Agreement is terminated by you, you may no longer use the WP that we have provided, regardless of any adaptations you have made to it. The WP is no longer to be seen as the WP that we have provided if more than 50% of the content has been replaced, in which case it may be kept despite termination of the Agreement.
Changes to the WP
The WP is to be seen as a “living document”, where we may make changes to the document. You are entitled to access to these changes, however you are not forced to implement them. The changes can be regarding formulations or be based on new recent praxises.