Notification and follow up of unacceptable circumstances
All employees, consultants, students and researchers working on behalf of NGI are encouraged to notify any unacceptable circumstances or misconduct, so that this may be dealt with and resolved. All NGI’s legal entities shall have procedures for notifying, (including whistleblowing), in line with national legislation and the principals stated below.
What are considered as unacceptable circumstances?
Unacceptable circumstances are violations of the law, the NGI Code of Conduct and other internal regulations or commonly accepted norms. Examples of circumstances that should be notified are threats to life and health, violation of NGI’s security regulations, threats to the external environment or climate, corruption or financial embezzlement, an unacceptable work environment, including harassment and bullying, violations of ethical norms for research and breaches of personal data protection rules. Professional disagreements and issues related to an employee’s employment terms are not normally considered as notifiable circumstances.
“All employees, consultants, students and researchers working on behalf of NGI are encouraged to notify any unacceptable circumstances or misconduct, so that this may be dealt with and resolved.”
Who to notify?
All unacceptable circumstances should be notified to the immediate superior. It this is not possible, other lines of reporting may be used. These are:
- Manager on a higher level
- Functions in the organization dedicated to following up undesirable circumstances or NGI’s ethical committee.
- Staff representatives
All employees also have the right to notify externally, in line with local legislation. If unacceptable circumstances are observed within a customer’s internal activities, this should be reported to the project manager and the head of section.
How to notify?
The employee should establish:
- Do I have grounds for my claims?
- How should I proceed with the information I have?
- How should I notify?
The person who sends a notification should give factual information. The notification should, as far as possible, be detailed, comprehensive and explanatory. A notification may be given in person, by phone, e-mail or in writing.
Employees may notify NGI anonymously, if this is not in conflict with national legislation.
Follow up of notifications, the notifier and the subject of the notification
All NGI’s legal entities shall have procedures for following up notifications, (including whistleblowing), in line with national legislation and the principles stated below.
- All notification shall be taken seriously and followed up.
- All notifiers shall within one week be given confirmation that the notification has been received.
- The notifier must be fairly treated and all forms of retaliation are prohibited.
- The subject(s) for the notification are entitled to legal protection.
- Confidentiality, impartiality and counteraccusation are the basic principles for the following up of notifications.
- All case managements shall be documented.
- All circumstances or behaviour confirmed as unacceptable must be dealt with and resolved.
- NGI’s ethical committee monitors the system to ensure the following up of notifications.