Whistleblowing Policy and Instructions


The Sigma group (the “Sigma Group”) is committed to high standards of ethical business conduct. In line with this commitment, this whistleblowing policy and instructions (the “Policy”) aim to provide a channel through which to raise concerns regarding suspected wrongdoings (as defined in section 2 below) within the Group. Please note that the reporting channels provided herein shall only be used for reporting of “whistle-blower”- wrongdoings as regulated by law and as further defined in section 2 below. Hence, wrongdoings that are not of public interest and only concern yourself or a limited number of individuals, are not covered by this Policy. Such other matters are to be addressed through other routines, e.g. as part of applicable HR-policies.

The specific Sigma company in which you are employed / have a relationship to, is below referred to as the“Company”. Unless otherwise stated below, references in this Policy will apply to the Company.

This Policy applies for the Company and all European group companies within the Sigma Group, except for companies within the Sigma Connectivity group which has a separate policy in place (the “Group Companies”).

The Group Companies shall provide all employees, trainees, hired personnel and members of the board of directors of the Group Companies with information on, and thereby increase their awareness of, the whistleblowing system on a periodic basis. This Policy shall be available and easily accessible for shareholders of the Group Companies.

It is the responsibility of each manager within the Sigma Group to ensure that this Policy is known and complied with within his or her respective area of responsibility. All employees and other individuals performing work for the Sigma Group shall familiarise themselves with this Policy and follow the contents of this Policy at all times.

The Sigma Group encourages reporting individuals to primarily contact their immediate managers to raise a concern. As a second option, individuals will have the possibility to report wrongdoings within a work-related context non-anonymously or anonymously through the Sigma Group’s internal reporting channels, in accordance with this Policy.

Definition of wrongdoing

A wrongdoing means any serious conduct that could have a negative impact on the Sigma Group’s business and/or operations or the working environment for the Sigma Group’s employees and/or business partners or any other serious conduct, provided in each case that there is a public interest that the wrongdoing comes to light.

Wrongdoing includes, but is not limited to, any actual or suspected:

  1. violation of laws (whether civil or criminal) and regulations;
  2. violation of the Company’s and/or Sigma Group’s policies, instructions and guidelines;
  3. bribery and corruption;
  4. serious risks concerning the life or health of individual persons (such as environmental crimes or major deficiencies in the security at a place of work);
  5. serious workplace deficiencies (such as systematic bullying, discrimination or harassment); and
  6. any other conduct that is inconsistent with the Company and/or Sigma Group’s core values.

Issues exclusively affecting the relationship between one or a limited number of individuals and a Group Company do generally not fall within the definition of wrongdoing for the purpose of this Policy. The Sigma Group encourages individuals to raise such concerns with their immediate manager and/or the HR department, depending on the circumstances.

Scope and responsibility

The following categories of individuals are encouraged to report any wrongdoing in accordance with this Policy.

This Policy shall also apply to individuals whose work-based relationship with a Group Company is yet to begin in cases where information on wrongdoings have been acquired during the recruitment process or other pre-contractual negotiations. In addition, this Policy shall apply to individuals who have acquired information within the context of a work-based relationship with a Group Company which has since ended.

If you have knowledge or serious suspicion of a wrongdoing, you are strongly encouraged by the Sigma Group to either inform one of the Sigma Group’s managers or file a report through the Sigma Group’s internal reporting channels. To file a report, you shall have reasonable grounds for believing that the information you are in possession of is true. However, it is not necessary to be able to present any evidence of the wrongdoing in order to file a report. As long as you act in good faith, you will not face any negative consequences regardless of whether the suspicion of a wrongdoing proves to be incorrect when the matter has been further investigated.


If you acquire information of a wrongdoing in a work-related context, you shall not be subject to any form of retaliation for reporting such information in good faith by way of using the Sigma Group’s internal reporting channels. For the purpose of this Policy, “retaliation” means any direct or indirect act or omission which occurs in a work-related context, is prompted by reporting information on wrongdoings, and which causes or may cause unjustified detriment to the reporting person. However, it should be noted that the protection against retaliation does not apply if it can be established that a criminal offence has been made when gathering the information for the report or if the report itself constitutes a criminal offence.

Data protection and privacy

Any processing of personal data will be made in compliance with applicable legislation. Processed personal data will be deleted within two years after the conclusion of an investigation, if an investigation is initiated as a result of a report of a wrongdoing. You will find more information regarding the Company’s processing of personal data in the Company’s Privacy Policy.

To the extent possible, information received in connection with a report will be treated as confidential and the privacy of the reporting individual and the subject of the report will be protected. However, please see the comments regarding potential disclosure under section 8 (the “Investigation”).

Internal reporting procedures

Reporting of wrongdoings should be made using one of the Company’s reporting channels as per the below. It is strongly recommended that the reporting channel ”Visslan” is used first-hand.

Investigation team

The Sigma Group’s investigation team consists of the whistleblowing function established at Danir AB, which is the parent company of the Sigma Group, currently represented by: Erik Ax, Legal Counsel at Danir AB, and Cecilia Tibatt, HR Manager at Danir AB, except in relation to the Sigma Technology Group, where the investigation team consists of Erik Ax and Niklas Börjesson, COO at Sigma Technology Group (the “Investigation Team”).

Reports of wrongdoings filed according to this Policy will be investigated by the Investigation Team. The InvestigationTeam will evaluate and assess the information received, ensure that the matter is investigated and recommend the appropriate course of action. The Investigation Team shall act independently and with integrity. The members are authorized by the Sigma Group and the Company to undertake the investigation measures they deem necessary and appropriate in each specific case. The Investigation Team reports directly to the Company’s CEO, or alternatively the chairman of the board of the Company, as relevant. If the subject of the investigation is the CEO or the chairman of the board of the Company, the Investigation Team shall instead report to the chairman of the board of Sigma Group. If the subject of the investigation also includes the aforementioned chairman of the board, the Investigation Team shall report to the CEO of Danir AB.

Furthermore, all members of the Investigation Team are bound by confidentiality undertakings regarding all information they receive in connection with the Sigma Group’s whistleblowing program and may not disseminate the information, except as provided in this Policy.

If a filed report concerns or relates to any member of the Investigation Team or concerns an issue or a business department in relation to which a member of the Investigation Team may have a conflict of interest, then such member shall not participate in the investigation of the report.

The investigation

The Investigation Team will, upon receipt and registration of a report of a wrongdoing, evaluate the report and determine the next steps. They may decide not to investigate a report, for example if (i) the information in the report is not relevant, (ii) there is insufficient information and/or evidence for an adequate investigation and no possibility of obtaining further information and/or evidence, or (iii) it can be established that the report has been made in bad faith. If the Investigation Team finds that the report is unfounded and shall not be further investigated, the report shall be deleted immediately.

If the Investigation Team decides to initiate an internal investigation, they shall inform the Company’s CEO, the responsible business area manager and/or the responsible manager of the division/function of the subject of the investigation.

The Investigation Team shall consider whether the responsibility for the next steps in the investigation should be assigned to relevant internal resources, for example IT, Legal, HR, Finance or a specific business area, as well as a potential need to engage external advisors. The investigation shall however always include an individual from a department/function outside the department/function which is the subject of the report.

The Investigation Team has the right to publish appropriate information regarding a report on the intranet or external website if deemed of interest for other parts of the Sigma Group or business partners, without disclosing your identity or the identity of the person or organization that is the subject of the report unless such disclosure is deemed strictly necessary and appropriate in a specific case.

The Investigation Team shall at all times conduct investigations discreetly, in the strictest confidence and with priority.

In conjunction with the investigation, or after the investigation has been completed, it may be necessary to disclose information which could identify you to functions within the Sigma Group, such as HR and or Legal, if justified in light of the relevant circumstances. Disclosure may also be made to competent authorities. You will be informed of such disclosure, provided however that informing you will not impede or complicate the purpose of the disclosure.

If you have filed a report, using the Sigma Group’s / the Company’s internal reporting procedures, and provided that you have done so through Visslan or otherwise non-anonymously, you will receive information on actions taken as follow-up to the report and the grounds for such follow-up within a reasonable timeframe but not later than three months from when you have received confirmation of receipt of the report, insofar as such information would not prejudice the internal enquiry or the investigation or affect the rights of any person concerned. If appropriate and attainable, you will be informed of the status of the investigation and any measures taken to address the issue raised on a continuous basis.

Course of action

When an investigation has been concluded, the Investigation Team shall recommend the appropriate course of action to, as first alternative: the Company’s CEO or, as second alternative (and if motivated in the relevant case), the chairman of the board of the Company, who shall thereupon decide on the course of action based on the Investigation Team’s recommendation(s). If the subject of the report is the CEO or the chairman of the board of the Company, the appropriate course of action shall be decided by the chairman of the board of Sigma Group. If the subject of the report is the aforementioned chairman of the board, the CEO of Danir AB shall ensure that corrective measures are implemented. The recipient of the Investigation Team’s recommendation shall on a continuous basis report back to the Investigation Team of the status of the corrective measures.

Actions shall be relevant, proportional and fair in relation to the interests of the Sigma Group and the Company as well as the individuals and organizations involved and shall take into consideration the relevant regulatory framework, corporate policies, culture and values. Actions can include measures such as a written warning or dismissal, or referrals to competent authorities for further investigation.


Reports received through the Sigma Group’s internal reporting channels shall be stored for no longer than necessary and proportionate in order to investigate the reported wrongdoing and undertake appropriate actions, however no longer than two years after a follow-up case or an investigation has been concluded.

The Investigation Team shall document all investigations properly and keep such records for archiving purposes. Documents from an investigation shall be kept no longer than necessary and proportionate.

Contact details

The investigation Team
If you have further questions regarding how we handle whistleblower cases, you are always welcome to contact the Investigation Team.

Erik Ax                                        
+46730 22 62 31

Cecilia Tibatt
+46703 79 02 78


Visslan (The Whistle Compliance Solutions AB)
For technical questions regarding Visslan’s platform, you may contact Visslan directly.

+4610 750 08 10

Daniel Vaknine (Direct number)
+4673 540 10 19

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