Integrity and honesty are core values at Ode. This whistleblowing policy is directly grounded in Ode's ethical guidelines (Etiske retningslinjer (Ikke tilgjengelig)), section 15, and elaborates on the specific procedures for receiving, handling and following up reports.
The purpose of the policy is to:
The whistleblowing policy applies to:
Everyone mentioned above may report without fear of retaliation, in line with section 2A-1 of the Working Environment Act.
Whistleblowing means reporting censurable conditions – that is, conditions that are in breach of applicable laws and regulations, Ode's ethical guidelines or generally accepted ethical norms.
Censurable conditions include, but are not limited to:
Personal employment matters, pay disputes and individual employment-law disputes normally fall outside the core scope of the whistleblowing scheme and are handled through ordinary HR channels.
3b. Food-safety nonconformities
All employees are obligated to report nonconformities in production, in buildings, or on products that may result in products not conforming to specifications or being unsafe to eat, as well as defects in packaging materials, equipment, or raw materials. This reporting obligation applies regardless of whether the nonconformity is considered minor or major. It is better to report a nonconformity that turns out to be insignificant than to let a serious nonconformity go undetected.
Food safety nonconformities differ from other reports in that they require immediate action:
External parties who wish to report food safety concerns may do so through our whistleblowing channel, EQS. In the case of serious nonconformities, it may be necessary to obtain additional information from the reporter to ensure a sufficient basis for immediate action. Ode therefore encourages food safety reports to be submitted with your name. All reports are treated confidentially, and the identity of the reporter will not be shared beyond those directly involved in handling and following up the nonconformity in question. Anonymous reporting is, however, always possible, both internally and externally. The Quality Department has access to food safety reports.
Reports can be made in writing and orally. Written reports are made via Ode's reporting channel in the quality system EQS, with the option of anonymous submission.
Both Ode employees and external partners can use reporting in EQS.
Varsling av kritikkverdige forhold / Reporting of censurable conditions (Ikke tilgjengelig)
4.1 External handling of reports
External handling of reports is relevant where the report is of such severity that external handling is necessary:
The choice of reporting channel is the whistleblower's right. Ode encourages reporting in EQS in the first instance but will never sanction anyone for reporting to an external supervisory authority.
It is essential that reports are always handled by a person who can deal with the case impartially. If the natural recipient is a party to the case, the report shall be escalated immediately to the next level. The report will move one level up until an impartial recipient is reached. Where no internal recipients are impartial, an external channel shall be used.
5.1 The Managing Director's responsibility
The Managing Director (CEO) has overall responsibility for ensuring that the whistleblowing system works in practice, that all employees are aware of the policy, that procedures for receipt and handling are operational, and that serious reports are reported to the board.
5.2 HR's responsibility
HR is the coordinating body for the reception and handling of reports in EQS. HR ensures that all reports are logged, assessed and followed up within set deadlines, and that correct escalation takes place. HR safeguards confidentiality and coordinates with management and, where necessary, external legal assistance.
5.3 Managers' responsibility
All managers are responsible for receiving oral reports in a supportive and non-judgemental manner, logging the report in EQS, implementing immediate measures where necessary, and escalating to HR if they are themselves involved or if the case requires it. Failing to pass on a report is a breach of Ode's Whistleblowing Policy and Ode's Ethical Guidelines.
5.4 Employee representatives' responsibility
Employee representatives shall receive training in the whistleblowing policy and may assist employees with advice on the reporting process. They may receive reports and shall pass these on to HR.
6.1 Receipt and acknowledgement
All reports shall be acknowledged as received to the whistleblower within 7 working days, provided the whistleblower has given contact information. In the case of an anonymous report, feedback is limited for practical reasons.
6.2 Assessment
The responsible person who receives the complaint has a duty to follow up the complaint and implement measures. The normal deadline for assessing a complaint is 30 days, but a longer deadline for handling may be set if necessary. The assessment determines whether the report falls within the scope of the whistleblowing policy, whether immediate measures are required, whether the case is to be handled internally or by an external investigator, and whether the board is to be informed.
In serious cases, the board is informed without undue delay. Where criminal matters are suspected, the police are notified.
6.3 Measures, conclusion and closure
After the assessment is completed, the responsible manager shall implement the necessary corrective measures. The whistleblower shall receive written feedback on the outcome to the extent that confidentiality considerations permit. All case documentation is archived and processed in accordance with the GDPR.
Reporting may be done anonymously via EQS. Ode respects the choice of anonymity, but it is important to be aware that anonymous reporting may make thorough investigation more difficult and limit the possibility of feedback.
The identity of a non-anonymous whistleblower is strictly confidential and shall only be known to those directly involved in the case handling. The person the report concerns shall not know the whistleblower's identity without the whistleblower's written consent.
Ode prohibits any form of retaliation against a person who reports in good faith – even if the report turns out to be based on incorrect factual premises. This also applies to the whistleblower's close family and colleagues.
Retaliation includes, but is not limited to: dismissal, demotion, exclusion from meetings, social exclusion, changes to work duties or threats.
A whistleblower who experiences retaliation shall report this immediately to HR or the CEO. Deliberately false reporting made in bad faith may result in disciplinary action in accordance with Ode's rules and applicable employment law.
All information relating to a report is strictly confidential. Only those directly involved in handling the report shall have access to the case information. Confidentiality applies throughout the entire process, including after the case is closed.
Information will only be shared beyond this if the law requires it, or if it is strictly necessary for carrying out an investigation.
All processing of personal data in connection with reports takes place in accordance with the Personal Data Act and the GDPR. Information collected shall not be used for purposes other than the case handling and is not archived longer than necessary.
The CEO and the board shall be reported to regularly on the number of reports, the category and the outcome of cases. The report shall not contain information that can identify individuals. The purpose of the reporting is to ensure that the whistleblowing system works as intended, to identify patterns and risk areas, and to give the board a sufficient overview to fulfil its supervisory responsibility.
Both the whistleblower and the person the report concerns may submit a written complaint about the way the case has been handled. The complaint is sent to HR and shall concern the process, not the substantive content of the case. The complaint shall be answered within 30 working days. If the complaint concerns HR, it is sent to the CEO. If the complaint concerns the CEO, it is sent to the chair of the board.
13. Training and awareness
All new employees shall be informed about the whistleblowing policy as part of onboarding. The policy is made available to all employees via EQS and Ode's internal channels. All managers and employee representatives shall complete training in the handling of reports. The policy is revised at least once every two years or when there are significant changes in laws and regulations.
14. Related documents