Whistleblower Policy

Munters, its subsidiaries and joint ventures are committed to the highest possible standards of openness, honesty and accountability. We expect our employees and business partners who have concerns about the Company’s behavior to communicate those concerns to us.

Employees are often the first to discover that there may be wrongdoings in the Company. However, the employee may decide not to express these concerns because of feeling that speaking up would be disloyal to colleagues or the Company. There may also be fear of harassment. In these circumstances it may be easier to ignore the issue rather than report it.

The purpose of this policy is to encourage employees to report matters without the risk of victimization or discrimination. This Policy enables employees to raise serious concerns they may have about matters occurring within or pertaining to the Company, rather than overlooking a problem or seeking a resolution of the problem outside Munters.

This Policy applies to all employees and business partners working for the Munters, our subsidiaries and joint ventures.

The Policy is a clear statement that if any wrongdoing by the Company or any of its employees, consultants, contractors or suppliers is reported, Munters will deal with it promptly and thoroughly investigate and correct it. We will further examine means of ensuring that such wrongdoing is prevented in future. We encourage our customers to alert us to any wrongdoings.

Definitions

Whistleblowing

Whistleblowing is attracting management's attention to information about potentially illegal and/or unethical practices, also known as wrongdoing.

Wrongdoing

  • Wrongdoing involves any unlawful or illegal behavior and can include:
  • An unlawful act, which may be civil or criminal
  • Failure to comply with any Company policy
  • Knowingly breaching local laws or regulations of any country
  • Unprofessional conduct
  • Questionable accounting, fraud or auditing practices
  • Practices likely to cause physical harm or damage to a person or to property
  • Failure to rectify, or take reasonable steps to report a matter likely to cause a significant and avoidable cost or loss to the Company
  • Abuse of power or authority for any unauthorized or purpose
  • Unfair discrimination such as discrimination based on age, race, gender, religion, sexual orientation, marital or maternity status, political opinion or ethnic back-ground in the course of the employment or provision of services
  • Conflicts of interest.
  • This is not an exhaustive list but rather examples of the kind of conduct, which might be considered wrongdoing.

Protection

Any employee who makes a disclosure or raises a concern under this Policy will be protected if the employee:

  • Discloses the information in good faith
  • Believes it to be substantially true
  • Does not act maliciously nor makes false allegations
  • Does not seek any personal or financial gain.

Process

Contact person

Anyone with a complaint or concern should contact his or her supervisor, manager or the person in charge of the department that provides the relevant service. The supervisor or manager will decide if the issue needs to be escalated to Senior Management based on the seriousness and sensitivity of the issues involved and the person suspected of wrongdoing.

If the complaint is in regard to your supervisor, manager or any other person in direct line of command for you, the following complaint path should be used:

The Chief Executive Officer, John-Peter Leesi, may be contacted via e-mail: johnpeter.leesi@luvata.com

Both can be contacted via ordinary mail to:

Munters AB
P.O. Box 1188
SE - 164 26 Kista
Sweden

Anonymous reports will be accepted.

Response

Munters will act upon any concerns raised. Please note that Munters can assess a concern only after having conducted an initial inquiry and, most likely, after duly investigating the matter in question.

Where appropriate, the matters raised may:

  • Be investigated by management, the Board of Directors, internal audit or through the disciplinary process
  • Be referred to the Police or other law enforcement authorities
  • Be referred to the independent auditor
  • Become subject of an independent inquiry.

In order to protect the individuals involved and those suspected of the alleged wrong-doing, an initial inquiry will be made to decide whether an investigation is appropriate and, if so, what form it should take. If urgent action is required; this will be taken before any investigation is conducted.

Within ten working days of a concern being raised, the responsible manager will communicate back to you:

  • Acknowledging that the concern has been received;
  • Indicating how the matter will be handled;
  • Giving an estimate of how long it will take to provide a final response;
  • Telling you whether an initial inquiry will be made; and
  • Telling you whether further investigations will take place and, if not, why not.

The amount of contact between the managers considering the issues and you will depend on the nature of the matters raised and the clarity of the information provided.

Munters will take steps to minimize any difficulties, which you may experience as a result of raising a concern. For instance, if you are required to give evidence in criminal or disciplinary proceedings, the Company will arrange for you to receive legal advice about the procedure.

Munters acknowledges that any person who raises concerns will need assurances that it has been addressed. Subject to legal constraints, the Company will provide information about the outcomes of any investigation as indicated above.

Time Scale

Concerns will be investigated as quickly as is practicable. It should be understood that it may be necessary to refer a matter to an external advisor and that this may result in an extension of the investigative process. The seriousness and complexity of a complaint may also have a negative impact upon the time taken to investigate the matter. The company will attempt to indicate at the outset the anticipated time scale for investigating the complaint.

Prevention of recriminations, victimization or harassment

The Company will not tolerate any attempt on the part of anyone to apply sanctions or to discriminate against any person who has reported to the Company a serious and genuine concern that they have regarding an apparent wrongdoing. Any such victimization will be dealt with swiftly and with strict disciplinary consequences.

Confidentiality and Anonymity

Munters will respect the confidentiality of any received whistle-blowing complaint where the complainant requests confidentiality. Anonymous complaints may be difficult to follow-up and verify if the person complaining is not prepared to give his or her name at a later stage.

False and Malicious Allegations

Munters strives to continue to meet the highest standards of honesty and integrity. We will ensure that sufficient resources are put into investigating any complaint, which it receives.

However, it is important for any employee contemplating making allegations to ensure that they are sincere.

The Company will regard the making of any deliberately false or malicious allegations by any employee of the Company as a serious disciplinary offence, which may result in disciplinary action, including dismissal.

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