Whistleblowing Report Channel

Union or national law concerning public procurement, financial services, food safety or consumer protection, for example, and reports the breach via a reporting channel. Reporting these breaches is important to prevent threats and serious harm to the public interest.

Whistleblower protection allows people to safely report breaches without their identity being compromised. The whistleblower’s identity remains confidential information in the subsequent processing of their report.

Whistleblower protection is based on the national Act on whistleblower protection (in Finnish) and the European Union’s whistleblower directive.

Whistleblower protection prohibits retaliation against the whistleblower. For example, an employer may not worsen a whistleblower’s terms of employment, dismiss them, or lay them off because of their report.

There are three general requirements for receiving whistleblower protection:

• The whistleblower has a reasonable belief at the time of reporting that the information regarding the breach is true. 
• The information regarding the breach falls within the scope of the Whistleblower Act. 
• The whistleblower must be reporting a breach they have discovered in the course of their work.

Breaches of European Union or national law may be reported, if they

• are punishable offences 
• may result in a penalty fee, or 
• may seriously endanger the realisation of public interest.

Reports may be made about breaches in the following sectors:

• public procurement, excluding defense and security procurement 
• financial services, products, and markets 
• prevention of money laundering and financing of terrorism 
• product safety and conformity 
• traffic safety 
• environmental protection 
• radiation and nuclear safety 
• food and feed safety, as well as animal health and welfare public health 
• public health within the meaning of Article 168 of the Treaty on the Functioning of the European Union 
• consumer protection 
• privacy and protection of personal data 
• security of networks and information systems.

In addition, the following may be reported:

• Violation of rules concerning European Union fund management or expenditure implementation or European Union income or fund collection 
• violation of rules related to the granting, use, or recovery of grants or state aid 
• violation of competition rules 
• violation of tax rules for businesses and corporations or arrangements made to obtain a tax advantage 
• violation of legislation enacted to protect consumers.

Whistleblower protection under the Whistleblower Act is given to the whistleblower who reports abuse detected in connection with their work.

The whistleblower may be

• an employee or official 
• an independent professional 
• a shareholder 
• a member of the board of a corporation or foundation or the Managing Director 
• a volunteer 
• a trainee.

The whistleblower may also make a report about a breach that occurred during negotiations prior to their employment or during a prior employment period. A report can be made, even if the negotiations did not result in their employment.

In addition, the protection extends to persons who assist the whistleblower in their reporting or are connected to the whistleblower and risk post-report retaliation because of their work or station. For example, the above could be a shop steward, trusted representative, health and safety representative, other employee representative, or the whistleblower’s contractual partner, colleague or relative.

A report on a possible abuse can be made to Palkeet’s reporting channel. Palkeet does not accept anonymous reports.

Familiarise yourself with the general requirements of whistleblower protection before making a report:

• The whistleblower has a reasonable belief at the time of reporting that the information regarding the breach is true. 
• The information regarding the breach falls within the scope of the Whistleblower Act. 
• The whistleblower must be reporting a breach they have discovered in the course of their work.

Intentionally providing false information is punishable, and it may result in liability for damages.

Always make the report primarily through Palkeet’s reporting channel. However, if you have a justified reason to believe that no action has been taken within a reasonable time frame based on the report submitted to Palkeet, or if the breach cannot be effectively addressed, or if you feel that you may be subject to retaliatory action due to the report, you may report a work-related wrongdoing under the Whistleblower Act to the centralised reporting channel of the Office of the Chancellor of Justice.

Proceed to make the report.

Upon submitting the report, you will receive a password. Please keep it safe. You will need the password to track the progress of your report. If you lose the password, you will not be able to track your report.

Track the processing of your report.

Read about the processing of personal data at Palkeet on the Data protection page.

1. The report of misconduct must be made in writing

The report must include the name of the whistleblower.  The system guides the process of making the report, and communication with the person making the report can be carried out through the system. The report can only be accessed by the people responsible for handling the report.

As a secondary option, reports falling under the scope of the Whistleblower Act can be made to the centralised reporting channel maintained by the Office of the Chancellor of Justice in situations covered by Section 8 of the Act. These situations may include cases where the person making the report has reasonable grounds to believe that adequate measures have not been taken within the prescribed period under Section 16 of the Act, that the breach cannot be effectively addressed on the basis of an internal report, or that the person making the report has reason to believe that they are at risk of retaliation due to making the report.

2. Receiving and Assessing Reports

In Palkeet, a designated and limited group of individuals responsible for processing activities investigate the matters. These individuals are named in Palkeet’s procedures.

The individuals responsible for processing activities may call upon other Palkeet officials or internal auditors as experts to handle a particular matter. If any of the designated individuals are disqualified, they will not participate in handling the matter.

If all designated individuals for processing activities are disqualified, the Managing Director of Palkeet will appoint new independent individuals to handle the matter. If the Managing Director is disqualified in the matter, the issue will be referred to the Ministry of Finance in accordance with the process determined by the Ministry.

The individuals designated for processing activities are responsible for the preliminary processing and assessment of the report. The processing activity first decides whether the notification falls under the scope of the Whistleblower Act, a misconduct report to be handled according to other applicable legislation, or an unrelated report that should be directed to another process, such as customer feedback.

3. Providing a notification or other response to the whistleblower

Palkeet will provide the whistleblower with a notice of receipt within seven days of receiving the report.

If the report does not clearly fall under the scope of the whistleblower channel as a misconduct report, the whistleblower will be notified of the transfer of the matter to another handling process or responsible party. Examples of this may include redirecting customer feedback to the appropriate process within Palkeet. If the report does not need to be transferred to another handling process or responsible party, the whistleblower will be notified that no further action will be taken. Such notification may be given e.g. for a completely inadequate or clearly unfounded report.

4. Assessing further investigation measures

If the report is a misconduct report that falls within the scope of the reporting channel, the individuals responsible for processing activities at Palkeet evaluate the necessary further investigation measures and, if necessary, call upon Palkeet’s own officials or internal auditors to investigate the matter.

5. Investigation of the report

The personnel responsible for processing activities, who have been designated for the processing function, are civil servants of Palkeet and coordinate the investigation. Experts called in to conduct the investigation will clarify and investigate the report and request additional information from the notifier through the report channel as necessary. If the notification proves to be accurate, the personnel responsible for processing activities will report the matter to the competent authority within the agency in accordance with Palkeet’s operating procedures, so that measures can be taken to address the breach. Based on their findings, the personnel responsible for processing activities will propose the necessary follow-up actions.

6. Communication of actions to the whistleblower

The persons responsible for handling reports of misconduct will inform the whistleblower of the follow-up measures within three months of the delivery of the notice of receipt of the report. The same method used for the notice of receipt of the report will be used to communicate the measures taken.

The information about the measures taken is provided to the extent that is possible within the three-month time limit, taking into account confidentiality and other considerations.

7. The results of the investigation, decisions on further action, corrective measures, and closure of the processing

As a result of the investigation, Palkeet will decide on further actions according to its procedures and implement them, or state that the report does not lead to any actions. Corrective measures may include e.g. the development of processes, controls or internal monitoring, contract matters, human resources management actions, filing a criminal report, legal actions, etc.

If the report of misconduct concerns the Managing Director, the investigation and decision on further actions will be transferred to the Ministry of Finance. Whenever possible, the whistleblower will be informed later about the final results of the investigation.

8. Documentation, registration and archiving of the matter concerning the report

Palkeet is responsible for storing the material generated during the processing of the report in accordance with the current legislation and the organisation’s archiving plan.

The persons responsible for the processing of the report create a file composed of the documentation from the reporting channel, which is archived into the case management system along with the decisions made regarding the matter.

After archiving, the documentation is removed from the technical reporting channel if the report was submitted through it. The public availability of the material is determined in accordance with the current legislation.