Orion Compliance Line

Read more about Orion Compliance Line

• What is Orion’s Compliance Line?

  Compliance Line is our secure and confidential reporting channel that supports our regular communications and reporting channels. It is externally hosted and maintained by an unaffiliated third party, and it is available to all Orion’s internal and external stakeholders. It is impossible for Orion to find out the IP addresses or other identification information related to reports sent via Compliance Line.

  
  Orion’s Compliance Line is intended for reporting activity within Orion that is: 

  
  1) deemed illegal, unsafe, or fraudulent, or 
  2) related to suspected misbehaviour or breach of our internal Code of Conduct and related policies. 

  
  Such whistleblowing topics include, but are not limited to fraud, theft, corruption, fraudulent financial reporting, conflicts of interest, human rights, competition law, data protection, environment, safety, trade compliance and violations of securities markets regulations (under the Finnish Securities Markets Act). 

  
  Please note that complaints related to employment and other HR matters (such as harassment and discrimination) should be primarily referred to Orion’s HR representatives.

  
  Orion’s Compliance Line is not intended for reporting urgent matters, such as situations threating employee safety or security, and that it is not a substitute for contacting law enforcement. 

  
  It is forbidden to report any information provided with the purpose of harming someone else, or that is intentionally false or unfounded. You do not need to have firm evidence of the wrongdoing before reporting it, but reports must be submitted honestly and in good faith. Reporting in bad faith may have legal consequences.

• How to Report Concerns via Orion’s Compliance Line?

  You can access Orion’s Compliance Line portal via this link. 

  This confidential reporting channel is secure, and it is impossible for Orion to find out the IP addresses or other identification information related to the report.

  Alternatively, you can also report directly to Orion’s Compliance Function by email to whistleblowing@orion.fi. All received emails are processed similarly than reports received via Compliance Line. 

  You can choose to disclose your identity in connection with the report or report anonymously. Please note, however, that concealing your identity may impact our chances of a successful investigation in the matter. In some cases, the investigation may not be completed without identifying all the relevant parties. Therefore, we recommend submitting your contact information so that you can be confidentially contacted, if needed, during the investigation process. 

• How the Reports Are Investigated?

  All received reports are investigated by Orion’s Head of Compliance or, by request of Head of Compliance, another independent function such as our Internal Audit. Investigation methods and approaches to handling concerns shall be thorough and consistent, but proportionate and appropriate to the circumstances of the case. The reporter is given a chance to be heard after submitting the report. The report is never used in decision-making without hearing the person(s) whom the report concerns. 

  The fact-based outcomes of substantiated investigations shall be appropriate to the findings, and they shall be decided by senior management ensuring objectivity and consistency of possible disciplinary actions. In significant misconduct cases or when otherwise applicable, Orion’s Ethics Forum, consisting of impartial members of the senior management, shall decide on the necessary corrective actions to be taken. 

  In accordance with the EU Whistleblowing Directive, the EU member states have established centralized external whistleblowing reporting channels. In certain cases, when permitted by the national laws, the whistleblowing reports can be submitted to such centralized reporting channels maintained by national authorities. For more information, see guidance issued by the national authorities. For example in Finland, the Office of the Chancellor of Justice has issued guidance on the use of its external reporting channel.

• Protection of Reporting Persons

  Any information the reporter provides via Compliance Line (or via whistleblowing@orion.fi address) will be treated in compliance with the whistleblower protection legislation. Orion does not tolerate any kind of retaliation against any person who, in good faith, reports suspected misconduct or participates in an investigation to resolve suspected misconduct. 

  In the investigation of compliance concerns, Orion ensures confidentiality for all parties involved. In criminal cases, the relevant parties will be informed that their identity may become public for legal reasons.

• Data protection

  Orion as the data controller, processes your personal information on the basis of its legitimate interests in order to develop and maintain good administrative practices (e.g. compliance with the rules and laws). You can read more about the protection and processing of your personal information by Orion in the Orion’s Compliance Line Information Notice.

  The person or persons whom the report concerns are covered by the data protection legislation related to the event or country. The persons are entitled to check their information and request corrections if the information is incorrect, incomplete or outdated. However, these rights are limited by the fact that the request must not result in the destruction of any evidence or limit or otherwise hinder the investigation. 

  All personal data will be processed according to Orion’s Compliance Line Information Notice.