Whistleblower scheme

The Air Greenland Group, which includes Air Greenland A/S, A/S Hotel Arctic and Greenland Travel, has decided to establish a whistleblower scheme for the Group’s employees, customers, suppliers and other external partners.

The aim of the whistleblower scheme is to ensure that an impartial and independent party can receive information about any irregularities outside of the Group’s management system. The whistleblower scheme is therefore a reporting channel that complements the current existing reporting channels.

Employees of the Group, customers, suppliers and other external partners can submit information to the Group’s whistleblower scheme about

  • a criminal offence, for example, misuse of funds, theft, fraud, corruption, gross violations of confidentiality, etc.
  • Serious infringements of legal regulations, internal rules and lack of compliance with legal obligations.

You can submit a report here https://airgreenland.whistleblowernetwork.net.

To secure your anonymity if you report via an Air Greenland network, you should:

  • Open a browser
  • Copy the whistleblower link to browser address
  • Press enter

Guidelines for Air Greenland’s whistleblower scheme

Purpose

Section 1 The Air Greenland Group, which includes Air Greenland A/S, A/S Hotel Arctic and Greenland Travel, has decided to establish a whistleblower scheme for the Group’s employees, customers, suppliers and other external partners.

The aim of the whistleblower scheme is to ensure that an impartial and independent party can receive information about any irregularities outside of the Group’s management system. The whistleblower scheme is therefore a reporting channel that complements the current existing reporting channels.

Paragraph 2 With a view to ensuring the impartiality of the scheme, administration is anchored with an external administrator. 

The right to provide information

Section 2 Employees of the Group, customers, suppliers and other external partners can submit information to the Group’s whistleblower scheme about

  • a criminal offence, for example, misuse of funds, theft, fraud, corruption, gross violations of confidentiality, etc.
  • Serious infringements of legal regulations, internal rules and lack of compliance with legal obligations.

Paragraph 2 The whistleblower scheme is only intended for those situations where the matter cannot be handled within the existing organisation, including the management system, union representative institution and Air Greenland Customer Service.

Paragraph 3 The whistleblower scheme does not therefore cover situations where special internal or external redress options have been established. For example, reports relating to aircraft operational or technical issues should be directed to the Danish Transport and Construction Agency via info@tbst.dk

Paragraph 4 Collaboration problems, dissatisfaction with management decisions and the like should not be reported via the whistleblower scheme, but must instead be handled in the normal way, for example, contact your line manager or the trade union representative.

Paragraph 5 If the report is filed in good faith, the person reporting (the whistleblower) is protected against any form of sanctions in relation to the report.

Anonymity

Section 3 Information covered by the whistleblower scheme can be reported anonymously or by name. 

Paragraph 2 If a whistleblower chooses to disclose their identity, the whistleblower may be called as a witness in any subsequent court proceedings. In that case the anonymity ends.

Paragraph 3 The external administrator does not record from which internet addresses a report comes from.

Processing information submitted to the whistleblower scheme

Section 4 The Danish Data Protection Agency is notified of the whistleblower scheme.

Section 5 The external administrator carries out the initial assessment of the information submitted to whistleblower scheme. All reports will be preliminary assessed within a maximum of 24 hours.

Paragraph 2 Information on matters that fall outside the purpose of the scheme, must be rejected by the administrator with a report back to the person who submitted the information. If the information is submitted anonymously, there will be no further action taken in the case.

Paragraph 3 The administrator shall carry out an assessment of the gravity of the matter and the options of documenting the matter through further investigations in order to determine whether the Group has acted or is acting in contravention of law, or otherwise has been guilty of serious maladministration.

Paragraph 4 The administrator shall forward information submitted to the system for processing by the designated contact person in the Group. The contact person shall further process the information according to internal practice.

Paragraph 5 The administrator shall, in specific cases where there are conflicts of interest, etc., consider it not appropriate to refer the matter to the Group contact person, and forward the information to the Group’s chairmanship. If the matter concerns the chairmanship, the administrator shall inform the entire Board of Directors.

Section 6 Persons who have information about them reported to whistleblower scheme, will be informed of the allegations, including what type of information it concerns, who the information will be passed on to, as well as about rules on access to and the option to correct the information.

Paragraph 2 The obligation to inform the person who has had information about them reported can, however, be postponed, if it is necessary to secure evidence and in some cases, it will not happen at all.

Follow-up

Section 7 The Chairman of Air Greenland shall be informed every quarter on the number and nature of reports to Air Greenland’s whistleblower scheme.