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What concerns can be reported, and how?

I’m directly employed by Hydro, what can I report?

  • We all have a responsibility to speak up promptly about potentially illegal, unethical or unwanted behavior. The right, and in some cases, the duty to report applies to all employees, as well as insourced personnel.
  • Hydro encourage employees to ask questions, seek guidance, raise concerns, and report suspected violations of regulation and internal procedures.
  • You can report any concerns about potentially illegal, unethical or unwanted behavior linked to Hydro’s operations and activities. Examples of behavior which should be reported include:
    • Corruption and bribery
    • Fraudulent accounting
    • Money laundering
    • Conflicts of interest
    • Unauthorized disclosure of trade secrets
    • Fictitious employment
    • Fraudulent invoicing
    • Tax evasion
    • Abuse of company funds
    • Community health and safety concerns
    • Business partner (supplier, contractor, joint venture, agency, etc.) misconduct (e.g., hazardous working conditions, harassment and discrimination, corruption and bribery)
    • Modern slavery
    • Other human rights breaches
  • Threats to safety or security and hazardous working conditions should normally be reported in IMS or Synergi.

Do employees have a duty to report?

  • Hydro encourage employees to ask questions, seek guidance, raise concerns, and report suspected violations of regulation and internal procedures.
  • As reflected in the Code of Conduct and Hydro Steering Documents, employees have a duty to report on:

How should employees report?

  • Normally, you should report concerns to your supervisor. If you are uncomfortable reporting to your supervisor, or you believe your supervisor has not appropriately addressed a concern, you can report to:
    • Your supervisor/manager’s manager
    • Your Plant/Location manager
    • Any member of Human Resources
    • Any member of Legal
    • Any member of Compliance
    • Any member of HSE
    • Any member of Group Internal Audit & Investigations
  • Hydro’s AlertLine can be used if you feel uncomfortable reporting to any of the other options listed above.

Are employees who report protected against retaliation?

  • Hydro will not tolerate retaliation against any employee who speaks up in good faith by asking a question, raising a concern, reporting a suspected violation or participating in an internal company investigation. Retaliation is taking negative action against someone for reporting a concern. Hydro’s Code of Conduct prohibits this act. At the same time, malicious and intentionally false reports will not be tolerated. Anyone who knowingly participates in retaliation or knowingly submits a false report will be subject to disciplinary action, including potential termination. If you suspect retaliation in the workplace, you must promptly report it to the Hydro AlertLine or one of the other reporting options above.

I’m not a direct Hydro employee, can I still report a concern?

  • Yes, you can report a concern through Hydro’s AlertLine. Please see «What kind of concerns can I report».

What kind of concerns can I report in Hydro’s AlertLine?

  • You can report concerns about potentially illegal, unethical or unwanted behavior linked to Hydro’s operations and activities.
  • Examples of behavior which should be reported include:
    • Corruption and bribery
    • Fraudulent accounting
    • Money laundering
    • Conflicts of interest
    • Unauthorized disclosure of trade secrets
    • Fictitious employment
    • Fraudulent invoicing
    • Tax evasion
    • Abuse of company funds
    • Community health and safety concerns
    • Business partner (supplier, contractor, joint venture, agency, etc.) misconduct (e.g., hazardous working conditions, harassment and discrimination, corruption and bribery)
    • Modern slavery
    • Other human rights breaches

What if I want to contact Hydro about other topics than illegal, unethical or unwanted behavior?

How will my concern be handled?

  • All concerns will be handled according to Hydro’s procedures for Alert Case Management and Internal Investigations.
  • Alerts reported through the AlertLine will be processed by Hydro Group Internal Audit & Investigations (GIA&I). Depending on the nature of the reported concern, GIA&I will decide how to pursue concerns reported through the AlertLine, including whether HR, Legal counsel, Finance functions, HSE, Sustainability, or other departments should be involved.
  • GIA&I is not part of Hydro's line organization, and will handle your concerns in confidence, with objectivity and professional discretion. Personal data is handled confidentially in accordance with the Information Handling Handbook. Throughout all stages of the process, GIA&I will do its utmost to protect the integrity of all persons involved.
  • Depending on the nature and severity of the reported concern, GIA&I could forward the alert to the relevant business area for further follow-up.
  • We encourage reporting, and will not retaliate against, individuals who in good faith raise concerns regarding illegal, unethical or unwanted behavior. Retaliation is taking negative action against someone for reporting a concern. Hydro’s Code of Conduct prohibits this act.
  • As stated in Hydro’s Human Rights Policy, in situations where we identify adverse human rights impact that we have caused or contributed to, we work to cooperate in, promote access to and/or provide fair remediation.

Can I report anonymously?

  • Yes, you can report anonymously using the AlertLine. Please check in later, using the log in credentials provided when you make the report, to check for any feedback or questions.
  • Throughout all stages of the process, GIA&I will do its utmost to protect the integrity of all persons involved. If you choose to identify yourself, GIA&I will work to protect any information disclosing your identity. However, GIA&I may need to reveal your identity to trusted partners if required as part of legal proceedings or an internal investigation. GIA&I will inform you prior to such disclosure and will focus on securing your integrity moving forward.
  • Depending on the content of the report, there could be some limitations on how we can follow up on anonymous reports.

Will my Identity be protected?

  • Throughout all stages of the process, GIA&I will do its utmost to protect the integrity of all persons involved. If you choose to identify yourself, GIA&I will work to protect any information disclosing your identity. However, GIA&I may need to reveal your identity to trusted partners if required as part of legal proceedings or an internal investigation. GIA&I will inform you prior to such disclosure and will focus on securing your integrity moving forward.
  • The AlertLine is operated in accordance with the Norwegian Working Environment Act and European data protection principles. Among other, this generally entails an obligation to inform individuals accused in an investigation report, who normally have the right to comment on and/or rectify factual circumstances. Unless otherwise agreed, information given to individuals mentioned in the report will not disclose your identity (if submitted).

Will I get feedback regarding my concern?

  • Yes, if you leave your contact information or log in to the AlertLine with the provided credentials.
  • Depending on the concern, laws and regulations, and data privacy rules, we may not always be able to release the full details of the report, investigation or follow-up activities.

What if something criminal has happened?

  • Authorities may want to talk to you, and your identity could potentially be required by the court. GIA&I will inform you prior to such disclosure and will focus on securing your integrity moving forward. Throughout all stages of the process, GIA&I will do its utmost to protect the integrity of all persons involved. If you choose to identify yourself, GIA&I will work to protect any information disclosing your identity.