FAQ – Whistleblowing Line

WHAT

What is Whistleblowing Line?

Whistleblowing Line is our web portal for filing whistle-blowing reports, security incidents, health & safety events, and grievances for breaches of human rights.

What is whistle-blowing?

Whistle-blowing means that an individual informs the company about a concern or suspected wrongdoing. This is to protect the company.

What is human rights grievance?

Grievance means a complaint about Telia Company breaching human rights of an individual or a group of individuals. This complaint can be filed in Whistleblowing Line.

What type of incidents should I report?

Incidents that you think violate our codes of conduct, other policies and instructions, or human rights. It may also be a violation of a law, rule, regulation and/or a direct threat to public interest.

For which countries can a report be filed?

Reports can be filed for incidents occurred in most of our locations; Denmark, Estonia, Finland, Latvia, Norway, Lithuania and Sweden.

What is retaliation?

Retaliation means that a reporter or an individual who have participated in an investigation as, for instance, a witness is punished in one way or another. The punishment might be changed job responsibilities or that the employment contract is terminated.

What if I face retaliation?

The company strictly forbids any retaliation against any person who reports a concern in good faith. Complaints made in good faith will not expose you to any sanctions, regardless of whether the underlying facts prove to be correct or result in any corrective action. If you believe you have faced retaliation of any kind, please report it so it can be investigated.

WHY

Why should I report what I know?

We all have the right to work in a positive environment. With that right comes the responsibility of acting in an ethical manner and letting the appropriate people know if someone is not acting in an ethical manner or violating any law or regulation. By working together, we can maintain a healthy and productive environment. Corporate misconduct can threaten the future of our entire company.

I am aware of some individuals involved with unethical conduct, but it doesn't affect me. Why should I report it?

Our company is committed to promote ethical behavior. All unethical conduct, at any level, ultimately hurts the company and all its employees, including you. If you know of any incidents of misconduct or ethical violations, consider it your duty to yourself and your co-workers to report it.

Does management really want me to report?

They certainly do. In fact, they need you to speak up. You know what is going on in our company - both good and bad things. The sooner we know the earlier we can act and hopefully minimize the negative impact of misconduct.

Isn’t this system just an example of someone watching over me?

Telia Company is committed to the highest possible standards of openness, honesty and accountability. In line with this commitment, we encourage and expect employees and others who have serious concerns about any aspect of the company’s work to come forward and voice those concerns. When you notice incidents that you think violate our codes of conduct, other policies and instructions, or human rights, you are encouraged to report them.

WHO

Who can use Whistleblowing Line?

Anyone can file a report on Whistleblowing Line as it is available on an external server outside Telia Company’s domain. Most reports are filed by employees, but it can also be consultants, suppliers, customers or other business partners.

Who receives the reports?

Specially trained employees are assessing the reports. Depending on what the report is about, different parts of Telia Company’s organization is responsible for the investigation. Reports concerning harassment, sexual harassment, discrimination, fair employment, poor leadership, wrongful terminations, forced or child labor will be assessed by Group People & Culture, while other categories of reports are assessed by the Special Investigations Office. Security incidents are taken care of by Security and health and safety incidents by local Human Resources.

HOW

If I as an employee have a concern, how should I report it?

When you observe some behavior, you believe violates our codes of conduct, we encourage you to report it. Ideally, you should bring any concerns forward to your direct manager, Human Resources department, Country Ethics & Compliance Officer or other member of our management team. We recognize, however, that there may be circumstances when you are not comfortable reporting the issue via the ordinary channels. That is why we have made the Whistleblowing Line available to you as an alternative reporting tool.

Are there other ways to report?

With Whistleblowing Line, you have the ability to file a report via the Internet by clicking the link: whistleblowingline.ethicspoint.com.

You can also e-mail Corporate Investigation on whistleblowing@teliacompany.com or send a letter to: Special Investigation Office, Group Security, Telia Company AB, Stjärntorget 1, 169 94 Solna, Sweden.

Where do these reports go? Who can access them?

Reports are entered directly into a secure server, which is hosted outside the Telia Company IT environment. Our service provider, GCS Compliance Services Europe Limited (“GCS EU”), with their EthicsPoint system, makes these reports available only to authorized individuals within Telia Company who are responsible for assessing the reports and start appropriate investigations. Each of these recipients is committed to keeping the reports confidential.

Will I get any feedback regarding the result of my filed report?

Depending on the sensitivity of the investigation, certain non-confidential information might be shared with the reporter. The final result of the investigation is never shared.



SECURITY & CONFIDENTIALITY

It is my understanding that any report I send from a company computer generates a server log that shows every website that my PC has connected with; won’t this log identify me as a report originator?

EthicsPoint does not generate or maintain any internal connection logs with IP addresses; no information linking your PC to EthicsPoint is available. In fact, EthicsPoint is contractually committed not to pursue a reporter’s identity.

If you feel uncomfortable making a report on your work PC, you have the option of using a computer outside your work environment (such as one located at an Internet café, the library, at a friend’s house, etc.) and connect to the Whistleblowing Line secure website.

Can I file a report from home and still remain anonymous?

A report from home, a neighbor’s computer, or any Internet portal will remain secure and provide you the ability to remain anonymous, where permitted by local laws. In addition, GCS EU does not generate or maintain Internet connection logs containing Internet Protocol (IP) addresses; no information linking you or your computer to GCS EU would be available if you choose to make a report.

I am concerned the information I provide will ultimately reveal my identity. How can you assure me that will not happen?

Your identity will always be kept confidential. You can also choose to be anonymous, where permitted by local laws. To further ensure your anonymity, you - as a reporting party - need to be careful not reveal any identifying details as part of your report. For example, “from my cube next to Jan Smith … ” or “in my 33 years … ” If you choose to be anonymous, remember to go back to your filed report after 7 days by using the report key and the password you have chosen when you filed the report as the investigator might have further questions to you. It might be more difficult to conduct a proper investigation where the reporter is anonymous so consider this seriously before submitting your report.

What if I want to be identified with my report?

There is a section in the report where you may identify yourself, if you wish. Hence, your identity will be kept confidential. The likelihood of a successful investigation is higher if you provide your identity.



TIPS & BEST PRACTICES

I am not sure if what I have observed or heard is a violation of company policy or involves unethical conduct, but it just does not look right to me. What should I do?

Ask Group Governance, Risk & Compliance by sending an e-mail to ask-us@teliacompany.com. We would rather you ask us about a situation that turns out to be harmless than let potential unethical behavior go unchecked because you were unsure.

What if my boss or other managers are involved in a violation? Won’t they get the report and start a cover-up?

The Whistleblowing Line and our investigation process are designed so implicated parties are not notified about the report or granted access to reports in which they have been named.

What if I remember something important about the incident after I filed the report?

When you file a report, you receive a unique report key and are asked to select a password. With the report key and your password, you can return to the Whistleblowing Line again and access your original report. At that point, you can add more details.

What if you have questions for me concerning my report?

At the end of your report, you will be provided with a report key and asked to create a password. With those two pieces of identification, you can follow up on the report by re-visit Whistleblowing Line. You are urged to check the report for questions or feedback from the investigation. This process means that situations can not only be identified but also be resolved, no matter how complex.

Are these follow-up reports as secure as the first one?

All Whistleblowing Line correspondence is treated in the same strict confidence as the initial report, continuing under the umbrella of anonymity (where applicable by law), if you so choose.