Whistleblower scheme

Coop’s whistleblower scheme can be used by employees as well as external business partners, business connections, suppliers, customers and members. 

For our employees, the whistleblower scheme is a supplement to internal dialogue and openness within Coop and is primarily intended for situations where the matter is of such a grave nature that it cannot be handled within the management system or via Internal Group Audit (IKR) because you wish to be completely anonymous. 

• Our employees are encouraged to discuss concerns with their line manager, the manager’s manager or HR, Legal or Internal Group Audit.

Matters relating to your own employment terms, working environment, disciplinary issues, pay or dissatisfaction with managerial decisions must as a rule be handled within the management system.

You may use the whistleblower scheme as follows:

The whistleblower scheme is intended for reporting:

• criminal offences, e.g. misuse of funding, fraud (e.g. manipulation of financial statements, embezzlement, or submission of incorrect information), substantial theft, fraud or serious violations of the duty of confidentiality
• serious violations of statutory provisions, internal rules and control procedures as well as non-compliance with legal obligations
• bribery or corruption (e.g. conflicts of interest, bribery, sponsorship and donations, gifts or facilitation payments) 
• acts committed by the management and/or the board of directors which cannot be reported via the local channels 
• non-compliance with competition laws (e.g. price-fixing, exchange of price-sensitive information, collusion with competitors) 
• serious threats to the environment, health and safety 
• activities that are otherwise defined in law, treaty or contract as constituting grossly inappropriate conduct (e.g. bullying, discrimination, sexual harassment, use of child labour, violation of human rights). 

You can read more about what the whistleblower scheme can be used for as well as your anonymity options under the “Description of the scheme” tab.

WHAT CAN BE REPORTED?

In the whistleblower system, you can report serious matters such as, e.g., bribery, extortion, embezzlement, theft, accounting irregularities, etc.
Matters such as dissatisfaction with wages, violations of the alcohol policy, etc., should not be reported here. They should instead be reported through the normal channels.

ANONYMITY

Coop has engaged the accountancy and consultancy firm Deloitte as the supplier of the whistleblower reporting platform and to manage Coop’s whistleblower system externally. This is to ensure completely anonymous handling of enquiries, if this is desired. 

All reports via the Coop whistleblower system will be kept confidential and anonymous unless you give your consent not to be anonymous. You have the opportunity to determine the level of anonymity you want. You can report in one of the following ways:

• including your name (in case of any future legal proceedings, you may be called as a witness)
• with full anonymity but with creation of an anonymous post-box   (you can be contacted via this post-box and still be 100% anonymous) 
• with full anonymity (you cannot be contacted for details)

OPEN A POST BOX

When you send the report, you have the option to choose whether you remain available for further inquiries by opening a secure post box.
We recommend that you make yourself available because we may not be able to finalise the case without further information from you.
When you create a post box, you will be given a case number, and you will choose a password. You will use the case number and password to log in to the post box in order to see if you have received any questions.
Regardless of whether or not you remain anonymous or you write your name, we ask you to open a post box. This makes it safer and easier for us to communicate.
All communication with us is anonymous if you wish it to be.

Description of the whistleblower scheme

At Coop, we want to run our business in accordance with applicable legislation and ethical standards. The aims of the Coop whistleblower scheme are: 

• to create a platform where our employees, business partners, business connections, customers and members can submit information about any irregularities through an impartial and independent party in an anonymised form 
• to ensure that anyone passing on information in the system will be protected from retaliation.

Units covered

Coop’s whistleblower scheme covers the following units:

• The Coop Group, except for Coop Bank and subsidiaries
• Coop Ferie (holiday) the free fund and Coop’s holiday fund
• The training and development fund for Coop and cooperative stores (the UU fund)
• The Training Fund for Coop salaried employees
• HB’s jubilæumsfond
• Coop Trading A/S
• The independent cooperatives

Reporting an incident 

We have established a procedure to ensure that the information you give us through the whistleblower system, including contact details, will be treated in strict confidence.

The reporting procedure is shown below:

Anonymity – if you want it

Coop has engaged the accountancy and consultancy firm Deloitte as the supplier of the whistleblower reporting platform and to manage Coop’s whistleblower system externally. This is to ensure completely anonymous handling of enquiries, if this is desired. 

All reports via the Coop whistleblower system will be kept confidential and anonymous unless you give your consent not to be anonymous. You have the opportunity to determine the level of anonymity you want. You can report in one of the following ways:

• including your name (in case of any future legal proceedings, you may be called as a witness)
• with full anonymity but with creation of an anonymous post-box (you can be contacted via this post-box and still be 100% anonymous) 
• with full anonymity (you cannot be contacted for details)

You may use the whistleblower scheme as follows:

The whistleblower scheme can be used to report justified suspicion or knowledge of:

• criminal offences, e.g. misuse of funding, fraud (e.g. manipulation of financial statements, embezzlement, or submission of incorrect information), substantial theft, fraud or serious violations of the duty of confidentiality
• serious violations of statutory provisions, internal rules and control procedures as well as non-compliance with legal obligations
• bribery or corruption (e.g. conflicts of interest, bribery, sponsorship and donations or gifts) 
• acts committed by the management and/or (local) boards that cannot be reported via the local channels 
• non-compliance with competition laws (e.g. price-fixing, exchange of price-sensitive information, collusion with competitors)
• serious threats to the environment, health and safety 
• activities that are otherwise defined in law, treaty or contract as constituting grossly inappropriate conduct (e.g. discrimination, sexual harassment, use of child labour, violation of human rights). 

You may not use the whistleblower scheme for the following purposes:

You cannot report problems with cooperation or dissatisfaction with managerial decisions. In those situations, you must contact your line manager, your manager’s manager, HR, Legal, Internal Group Audit or a trade union representative.

Guarantee of strict confidentiality

The aims of the Coop whistleblower scheme are: 

• to create a platform where our employees, business partners, business connections, customers and members can submit information, anonymously and via an impartial and independent third party, about any irregularities 
• to ensure that everyone who passes on information using the system will be protected from retaliation.

In order to give you, the reporting party, full confidentiality, Coop has signed an agreement with Deloitte to administer the scheme.

Read more about the whistleblower scheme

You can read more about the whistleblower scheme in Coop’s whistleblower policy.