Whistleblowing Policy

The purpose of the Whistleblower policy is to enhance the discovery of misconduct and irregularities within the organization. The Swedish Whistleblowing Act (Sw. lagen om skydd för personer som rapporterar om missförhållanden, 2021:890). provides protection for individuals who, in a work-related context, have received or obtained information about wrongdoing of public interest and report it.

This policy aims to provide a comprehensive framework and knowledge of the Whistleblowing procedures of Thunderkick AB. Applicable to all Thunderkick AB employees, and other in scope individuals as outlined under Section 2, it is the responsibility of each individual to ensure compliance with these standards in daily professional activities. We are committed to conducting our business with honesty and integrity, and we expect all employees to maintain high standards in accordance with our policies and procedures. In the event of potential wrongdoing or unknowingly harbouring illegal or unethical conduct, employees often become the first to recognize that there may be a serious issue within the company. A culture of openness and accountability is essential to prevent such situations from occurring and to address them when they arise.

The purpose of the Whistleblowing Policy is to promote that misconduct and irregularities within the organization are discovered and addressed adequately.

Who can use the whistleblowing channel?

To enjoy protection under the Swedish Whistleblowing Act, individuals must have received information about misconduct within Thunderkick AB in a work-related context. The personal scope includes:

Employees and persons making inquiries about or seeking work at Thunderkick AB,
Individuals applying for or performing volunteer work at Thunderkick AB,
Persons applying for or completing an internship at Thunderkick AB,
Individuals available to carry out or currently carrying out work under Thunderkick AB’s control and direction such as freelancers, consultants, service providers,
Self-employed workers seeking work at Thunderkick AB,
Shareholders, directors, members of a supervisory board or other boards, and
Individuals who have belonged to one of the above categories and have received or obtained information in their role during the time of their engagement

What can be reported through the whistleblowing channel?

Under Swedish law the list of concerns that fall within the scope of the Whistleblowing Act include:

breaches of European Union law;
breaches of Swedish law implementing or complementing European Union law; and
concerns that are of such nature that it is of public interest that they are reported (for example violations of human rights, corruption, embezzlement, human trafficking etc.)

Concerns that are of purely personal nature, e.g. relating to the reporting person’s own employment relationship, do typically not fall within the scope of matters that may be reported through the whistleblowing channel. Instead, such concerns shall be addressed directly with the line manager, the HR or the CEO.

In order to enjoy protection under the Whistleblowing Act the whistleblower must furthermore have had reasonable grounds to believe that the information disclosed was true at the time of reporting.

How do you report a suspected wrongdoing?

Reports can be submitted:

By email: File a report in writing by emailing to: whistleblowing@thunderkick.com

By mail: File a report in writing by sending a letter to Interna Visselblåsarfunktionen, Thunderkick AB, Vasagatan 11, 111 20 Stockholm.

By phone: Call 073-4296589 and ask to speak to the internal whistleblowing function regarding suspicious misconduct.

In-person meeting: Request a physical meeting with the designated impartial person below.

Wan Kim, Head of compliance, wan.kim@thunderkick.com

Emelie Alm, HR Manager, emelie.alm@thunderkick.com

By using Thunderkick’s internal reporting channels described above and ensuring that the suspected wrongdoing in question falls within the scope of the country specific provisions, you are protected against retaliation under the Swedish Whistleblowing Act.

What should the report include?

Your whistleblowing report should contain the following information:

Your name and contact details (optional).
The type of misconduct/incident you want to report.
Where and when the misconduct/incident occurred.
How it happened, with specific dates and times if possible.
Individuals involved.
Any available documentation regarding the misconduct.
Information about whether you have notified another body or person about the misconduct.
Clearly state that your disclosure is within the Thunderkick Whistleblowing Policy.

Protection of the Whistleblower

The identity of the whistleblower is subject to absolute confidentiality. No one, apart from the individuals strictly necessary to assess and investigate the errand, can obtain your contact details. You can choose to remain anonymous, however to facilitate a more efficient investigation and feedback process we encourage you to share your contact details. In addition, by providing your contact details you will receive feedback about what measures are taken in relation to your report. Thunderkick AB is committed to treating all disclosures in a confidential and sensitive manner. The identity of the individual making the allegation is kept confidential as long as it does not hinder or frustrate any investigation. The whistleblower can choose not to reveal their identity.

Thunderkick AB retains records of all reportable concerns that we receive. The records are not retained longer than necessary, and they are deleted within two years from when the follow-up of the reportable concern has been ended.

Please note that under the Swedish Freedom of Press Act (Sw. tryckfrihetsförordningen) and the Swedish Fundamental Law on Freedom of Expression (Sw. yttrandefrihetsgrundlagen) everyone is free to communicate information on any subject whatsoever for the purpose of publication in programmes or technical recordings (freedom to communicate information, Sw. meddelarfrihet) as well as right to procure information on any subject whatsoever in order to communicate or publish it (freedom to procure information, Sw. anskaffarfrihet). Your duty of loyalty to your employer may restrict these rights.

Investigation procedure

Upon receiving a report, the Thunderkick AB’s whistleblower function will follow these steps:

Notification: Receipt of the report will be acknowledged by the designated impartial person within seven days of the report being made.

Assessment and investigation: An initial assessment is conducted by the designated impartial person. If the errand falls within the scope of the Swedish Whistleblowing Act an investigation shall be carried out.

Feedback: The whistleblower will be provided feedback on any measures envisaged or taken as follow-up to the report, subject to applicable legal and regulatory obligations, within three months upon the date of receipt of the report.

External reporting

In addition to the internal whistleblowing channel provided by Thunderkick, you may also report the suspected wrongdoing by using external whistleblowing channels provided by competent authorities in Sweden. Please find a list of competent authorities in Sweden who maintain external reporting channels below. The best way to obtain the authority’s contact details is to go on their website.

Authority	The Authority’s Area of Responsibility
Konkurrensverket	Breaches falling within the scope of public procurement that is covered by the authority’s supervisory responsibility.
Fastighetsmäklarinspektionen, Finansinspektionen, länsstyrelserna i Stockholms, Västra Götalands och Skåne län, Revisorsinspektionen och Spelinspektionen.	Breaches falling within the scope of financial services, products and markets, and prevention of money laundering and terrorist financing that is covered by the authority’s supervisory responsibility.
Arbetsmiljöverket, Boverket, Elsäkerhetsverket, Folkhälsomyndigheten, Inspektionen för strategiska produkter, Kemikalieinspektionen, Konsumentverket, Livsmedelsverket, Läkemedelsverket, länsstyrelserna, Myndigheten för samhällsskydd och beredskap, Naturvårdsverket, Post- och telestyrelsen, Statens energimyndighet, Statens jordbruksverk, Styrelsen för ackreditering och teknisk kontroll och Transportstyrelsen.	Breaches falling within the scope of product safety and compliance that is covered by the authority’s supervisory responsibility.
Transportstyrelsen	Breaches falling within the scope of transport safety that is covered by the authority’s supervisory responsibility.
Havs- och vattenmyndigheten, Kemikalieinspektionen, Livsmedelsverket, länsstyrelserna, Naturvårdsverket, Skogsstyrelsen och Statens jordbruksverk.	Breaches falling within the scope of protection of the environment that is covered by the authority’s supervisory responsibility.
Livsmedelsverket och Strålsäkerhetsmyndigheten.	Breaches falling within the scope of radiation protection and nuclear safety that is covered by the authority’s supervisory responsibility.
Livsmedelsverket och Statens jordbruksverk.	Breaches falling within the scope of food and feed safety, animal health and welfare that is covered by the authority’s supervisory responsibility.
Folkhälsomyndigheten, Inspektionen för vård och omsorg, Konsumentverket och Läkemedelsverket.	Breaches falling within the scope of public health that is covered by the authority’s supervisory responsibility
Finansinspektionen och Konsumentverket.	Breaches falling within the scope of consumer protection that is covered by the authority’s supervisory responsibility
Finansinspektionen, Inspektionen för vård och omsorg, Integritetsskyddsmyndigheten, Livsmedelsverket, Post- och telestyrelsen, Statens energimyndighet och Transportstyrelsen.	Breaches falling within the scope of protection of privacy and personal data, and security of network and information systems that is covered by the authority’s supervisory responsibility
Ekobrottsmyndigheten	Breaches falling within the scope of the union’s financial interests as referred to in 2.1 b Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019, regarding fraud.
Skatteverket	Breaches falling within the scope of the union’s financial interests as referred to in 2.1 b Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019, regarding taxes.
Regeringskansliet	Breaches falling within the scope of the union’s financial interests as referred to in 2.1 b Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019, regarding state aid.
Konkurrensverket	Breaches falling within the scope of the union’s financial interests as referred to in 2.1 b Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019, regarding the area of competition.
Regeringskansliet	Breaches falling within the scope of the union’s financial interests as referred to in 2.1 b Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019, regarding the area of state aid.
Skatteverket	Breaches falling within the scope of the union’s financial interests as referred to in 2.1 b Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019, regarding corporate taxes.
Arbetsmiljöverket	Breaches not covered by another authority’s supervisory responsibility.

Responsible for this Policy

HR has the overall responsibility for the Whistleblowing Policy and are responsible for a yearly review.