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Whistleblowing policy

A whistleblowing policy is a safe and anonymous option of “blowing the whistle” if you experience or suspect that unlawful activities are taking place within the Lundbeck Foundation or in operations related to the Foundation.

The Lundbeck Foundation is a responsible industrial foundation with an open culture, where everyone can speak their mind, not least if you experience any irregularities or illegalities.

Normally the preferred procedure is to talk to the responsible manager or the CEO of the Foundation. If you do not feel that you can speak with anyone within management, you can file a report - anonymous or not - in The Lundbeck Foundation's whistleblower solution.

In the whistleblower solution employees and other actors related to The Lundbeck Foundation can in good faith make anonymous or non-anonymous reports regarding serious issues, including issues that might cause The Lundbeck Foundation to suffer an economic loss or hurt its reputation.

The purpose of the whistleblower terms described below is to explain how the whistleblower solution works and thereby avoid any potential restrains regarding reporting of important matters. 

Who can submit a report? 

Reports can be submitted by The Lundbeck Foundation’s employees, employees in The Lundbeck Foundation's subsidiaries and people related to The Lundbeck Foundation. People related to The Lundbeck Foundation could for example be applicants for grants, recipients of grants, suppliers or external consultants. 

Who can be reported? 

There can be reported on matters involving employees of The Lundbeck Foundation or other people connected with the foundation. 

People connected with the foundation could for example be board members, internal and external reviewers, auditors, lawyers and suppliers.

What issues can be reported?

The whistleblower solution can only be used to report serious issues. Serious issues refer to violations of the law, internal rules, guidelines or such.

Less serious issues such as: dissatisfaction with wages, difficulties in cooperation, violation of smoking or alcohol policy, etc. cannot be reported through the whistleblower system. Such issues have to be reported through the normal channels, e.g. by contacting the immediate manager directly. 

Serious issues that can be reported through the whistleblower system are for example information about:

  • Financial crime such as embezzlement, bribery, fraud and forgery,
  • Submission of false or misleading information to public institutions,
  • Violation of the foundation's code of conduct,
  • Physical violence and sexual offenses,
  • Corruption,
  • Nepotism,
  • Irregularities regarding accounting or audit.

The above mentioned irregularities are only examples. If you are in doubt whether you should report an issue or not we recommend that you do it. We answer and handle all the reports, and your help is essential for us. The worst that can happen is that you will learn where you can address your issue if it is not possible to addres it through the whistleblower system. 

Who manages the reports? 

The reports are managed by the Executive Assistant, who reports directly to The Lundbeck Foundation’s board of directors. In this manner no conflict of interest will occur. If we receive a report that requires translation, this will be done by Human Time A/S, which is the supplier of the whistleblower portal. 

How are the reports processed? 

When a report is received, a preliminary investigation of the issue is made.

If the report turns out to be clearly unfounded, it will be deleted from the system immediately and the employee who submitted the report will be informed.

If the report turns out to be founded, further investigation will be made. The case is investigated internally and can have employment consequences for the person whom the report concerns. The case is deleted from the system but it is kept up to five years in the staff dossier of the reported employee. The case can also be sent to the police for further investigation if required. When the police (and possibly the court of justice) have completed the case investigation, the case is deleted from the system. The person under police investigation might end up in the court of law and further get a fine and/or imprisonment.

It is important that the system is not used for making false accusations, where innocent people fall under suspicion. Therefore, all reports must be submitted in good faith. If a report is submitted in bad faith and it is based on personal negative feelings such as revenge, it might have negative employment consequences for the whistleblower, if he/she can be identified. 

How can a report be submitted?

You can fill in a report through the internet portal https://lundbeckfonden.whistleblowernetwork.net It is not possible to submit a report by other means, e.g. by sending an e-mail to the person in charge of the whistleblower system. This is due to the fact that the report might contain confidential personal information that should not be transmitted unencrypted through the internet. Because everyone should have the possibility to use the internet portal, it is possible to report an issue in one’s native language. 

It is also possible to follow the course of the issue reported. When a person submits a report, he/she is given the option to log in anonymously in the system at a later time and see if the examiner has asked additional questions to the case or asked for supplementary documentation. Any subsequent dialogue is 100% anonymous and is based solely on the whistleblower’s willingness to log into the system and answer to the examiner’s questions. 

Anonymity and IT security 

The whistleblower can choose if the report is submitted anonymously or not. 

All reports submitted in good faith are protected against any form of reprisals. Anyone who tries to exercise reprisals against a whistleblower will be subject of sanctions based on the employment law. 

If the whistleblower chooses not to be anonymous, the foundation will respect the whistleblower’s wish to be anonymous as much as possible. However, if a non-anonymous report ends up in a court of law, the whistleblower risks to be called in as a witness. 

Only the examiner who investigates the case has the password to access the system. 

Information about the registration to the reported person 

The foundation is obliged to inform the reported person about the issue reported. However, it will be individually evaluated when the reported person will be informed, in order to avoid potential obstruction of the investigation and gathering of evidence. 

No information will be provided about who made the report, even though the whistleblower chooses not to be anonymous. However, please note that non-anonymous whistleblowers can risk to be called in as a witness, if the case is ending up with a case court as mentioned above.