Click HERE to view the full version of the Swedish Whistleblowing Act (Protections for Persons Reporting Irregularities Act (SFS 2021:890)). Chapter 5 describes requirements for internal reporting channels and procedures for reporting and follow-up.

According to whistleblowing legislation, business operators are obliged to provide clear and easily accessible information about

1. How to report via internal reporting channels;
2. How to report to competent authorities via external reporting channels and, where applicable, to EU institutions, bodies or agencies; and
3. Freedom to disclose and to acquire information and, in business operations where it is relevant, the prohibition of investigation and retaliation.

Below is a text proposal based on the above requirements.

REPORTING VIA INTERNAL WHISTLEBLOWING CHANNELS

Reporting can take place in writing via the website wb.2secure.se or verbally by phone at 077-177 99 77. You can choose to remain anonymous in both of these reporting channels. If you would like to report via an in-person meeting, this can be requested by registering a report on the website wb.2secure.se. The in-person meeting will be held by agreement either with a representative from TOBII or with TOBII’s provider of whistleblowing services, 2Secure.

When registering a new report on wb.2secure.se, you must state the company-specific code tob637 to identify that the report is being made for TOBII. On the website, you will be asked to answer a number of questions about the matter to which the report relates. You can remain anonymous and are assigned a unique case number and password, which must be saved so that you can actively log in to the website, monitor the report and communicate with the case officer at 2Secure.

Once a report has been registered, it is processed by experienced case officers at 2Secure, who will contact TOBII’s primary contact person based on a predetermined contact list with several names. If the primary contact person is the subject of the report, another person on the contact list will be informed. It is always TOBII who ultimately assesses the report and decides what measures are to be taken.

REPORTING VIA EXTERNAL WHISTLEBLOWING CHANNELS

In addition to reporting to TOBII's internal whistleblower channel, you can report externally to a competent authority within a specific area of ​​responsibility or to one of the EU institutions, bodies and agencies. The following authorities have been appointed as competent authorities and established external reporting channels: Swedish Work Environment Authority, National Board of Housing, Building and Planning, National Electrical Safety Board, Swedish Economic Crime Authority, Swedish Estate Agents Inspectorate, Swedish Financial Supervisory Authority, Public Health Agency of Sweden, Swedish Agency for Marine and Water Management, Swedish Authority for Privacy Protection, Inspectorate of Strategic Products, Health and Social Care Inspectorate, Swedish Chemicals Agency, Swedish Consumer Agency, Swedish Competition Authority, Swedish Food Agency, Medical Products Agency, The county administrative boards, Swedish Civil Contingencies Agency, Swedish Environmental Protection Agency, Swedish Post and Telecom Authority, Government Offices, Swedish Inspectorate of Auditors, Swedish Tax Agency, Swedish Forest Agency, Swedish Gambling Authority, Swedish Energy Agency, Swedish Board of Agriculture, Swedish Board for Accreditation and Conformity Assessment, Swedish Radiation Safety Authority and Swedish Transport Agency.

ABOUT STATUTORY INFORMANT PROTECTION

In addition to the ability to report suspected irregularities in accordance with whistleblowing legislation, there is also a right to freedom of disclosure and acquisition in accordance with the Swedish Freedom of the Press Act and the Swedish Fundamental Law on Freedom of Expression. This means that it is possible for an employee (with certain exceptions) in both private and public sectors to submit with impunity otherwise confidential information for publication to mass media covered by the Swedish Freedom of the Press Act and the Swedish Fundamental Law on Freedom of Expression.

There is also extended protection for employees in public sector organisations or other operations where informant protection applies in accordance with the Swedish Informant Protection in Certain Sectors of Economic Activity Act (SFS 2017:151) or the Swedish Public Access to Information and Secrecy Act (SFS 2009:400). This extended protection relates to a prohibition against investigation and a prohibition against retaliation.

The prohibition against investigation means that a government agency or other public body may not, as a general rule, investigate who has submitted a notification for publication.

The prohibition against retaliation means that the general public may not take measures that have negative consequences for an individual because he or she has exercised his or her freedom of expression and disclosure.

Violations of the prohibitions against investigation and retaliation are punishable by fines or imprisonment for a maximum of one year (Chapter 3, Section 4 of the Swedish freedom of the Press Act and Chapter 2, Section 4 of the Swedish Fundamental Law on Freedom of Expression).

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