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BIG is committed to lawful and ethical behavior in all our activities and requires employees, executives and partners to act in accordance with applicable laws, regulations and policies and to observe high standards of business and personal ethics in the conduct of their duties and responsibilities.
The BIG Ethics Hotline applies to all employees, executives and partners of BIG as well as applicants and former employees of BIG or any other person that in any event can relate to BIG. Such persons are strongly encouraged to share their concerns about a violation or potential violation in accordance with the BIG Ethics Hotline under which the reporting persons will receive protection.
The BIG Ethics Hotline applies to all employees, executives and partners of BIG as well as applicants and former employees of BIG or any other person that in any event can relate to BIG.
The BIG Ethics Hotline applies to reports of any actual or potential violation that:
(i) Relates to EU, Spanish and Danish law (e.g., fraud, money laundering or public procurement offences, environmental protection, public health and consumer and data protection), as well as
(ii) Reports of serious offenses or other serious matters such as sexual harassment, duty of confidentiality, misuse of financial means (embezzlement, bribery, fraud, theft etc.), serious harassment due to race, political or religious affiliation etc.
If in doubt whether to report an observation or experience, we strongly
encourage you to do so.
All reports will be processed and responded to.
Reports on a person’s own employment, personnel conflicts, or personal matters as well as violations of internal guidelines and rules will in principle fall outside the scope of BIG Ethics Hotline. Except in case of serious and repeated breach, reports and information regarding these matters, shall be reported to the People Team, your superior or the Managing Director by direct email (non-anonymous) or by using BIG People Hotline formular on BIG.net (anonymous).
Reporting persons can submit a report by using the online formular found below (anonymous) or by writing to the following email: [email protected] (non-anonymous).
All reporting persons receive immediate protection under BIG Ethics Hotline, provided they had reasonable grounds to believe that the reported information was true at the time of reporting and that such information fell within the scope of BIG Ethics Hotline. This means that all reporting persons must be acting in good faith. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense. Furthermore, the reporting persons will not be protected under BIG Ethics Hotline.
People who report do not incur any liability for having breached an obligation of professional secrecy, provided they had reasonable grounds to believe that the reported information was necessary to reveal an actual or potential violation.
No reporting person who makes a good faith report under BIG Ethics Hotline or any third party who cooperates in inquiries or investigations shall suffer harassment, retaliation, or adverse employment consequence. Any reporting person who believes that he or she has been subjected to any form of retaliation because of making a good faith report under BIG Ethics Hotline should immediately report the retaliation to the CEO or the Chairman of the Board of Directors by email.
BIG Ethics Hotline is operated in a secure manner that ensures that confidentiality of (i) the identity of the reporting person, (ii) the identity of a person who is referred to in the report as a person to whom the violation is attributed and (iii) any third party mentioned in the report is protected and (iv) prevents access thereto by non-authorized staff members.
Reports under the BIG Ethics Hotline will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation. Furthermore, if a report results in a lawsuit being initiated against the reported person, the reporting person risks being called as a witness in the trial.
The Ethics Responsible Team will upon receipt of a reporting notify the reporting person and acknowledge receipt of the reported violation or suspected violation within seven calendar days.
All reports will be promptly investigated in an independent manner intended to establish trust and protect confidentiality, consistent with a full and fair investigation. Appropriate corrective action will be taken if warranted by the investigation. Where necessary, the reporting person may be asked for further information, albeit without there being an obligation to provide such information.
Reporting persons will receive information on the action envisaged or taken as a follow-up on the reporting and the grounds for the choice of follow-up (“feedback”). Follow-up can include, for instance, referral to other channels, launch of an internal enquiry, any measures taken to address the issue raised, or closure of the procedure based on lack of sufficient evidence or other grounds.
The feedback will be provided within three months from the acknowledgment of receipt was sent to the reporting person. Where the appropriate follow-up is still being determined, the reporting person will be informed about this and about any further feedback to expect.
A summary of the report, follow-up and feedback will be registered for record and to be presented to the Managing Director, local partner group and the CEO on a regular basis.
BIG strongly encourage anyone who wishes to raise a concern to do so through BIG Ethics Hotline prior to seeking resolution outside BIG.
However, it is also possible to report externally to The Danish Data Protection Agency through The National Whistleblower Scheme (https://whistleblower.dk/english) or to The Spanish Autoridad Independiente de Protección del Informante (the “AAI”).
