Reel is committed to the highest standards of ethical, moral, and legal business conduct. In line with this commitment, and Reel’s commitment to open communication, this policy aims to provide an avenue for employees and external parties to report severe misconducts which have occurred or are very likely to occur, including breaches of our Code of Conduct. Moreover, it ensures that they can do so with confidence of protection from retaliation, discrimination, or disadvantage.
This Whistleblower Policy is an important tool for reducing risks and maintaining trust in our operations by enabling us to detect and act at an early stage.
This Whistleblower Policy is based on Denmark’s Whistleblower Protection Act (Act no. 1436 of 29/06/2021), Directive (EU) 2019/1937 of the European Parliament and of the Council on the protection of persons who report breaches of Union law (the “Directive”), and applicable rules on data protection.
This policy applies to all employees (whether permanent, fixed-term, or temporary), trainees, seconded staff, volunteers, or interns, hereafter referred to collectively as employees.
All employees have a duty to be aware of the contents of these guidelines and any updates to them, and to comply therewith.
External parties who have been in a work-related context with Reel may instead use an external whistleblower hotline.
All employees may report suspected misconducts when a misconduct becomes apparent in our organisation.
A “misconduct” means an act or omission occurred (or most likely to occur) in our organisation which is considered harmful to the public interest, which the employee has received knowledge of in a work-related context.
Misconducts that should be reported under this policy include, but are not limited to: