Whistleblower protection and Haaga-Helia's internal whistleblowing channel

Whistleblower protection allows you to safely report a breach you have discovered and protect yourself against possible retaliation.

However, to qualify for whistleblower protection, three general conditions must be met:

• at the time of notification, you must have reasonable grounds to believe that the information about the breach is correct,
• the information about the breach is covered by the Whistleblower Protection Act, and
• you are reporting a breach you have discovered in the course of your work.

You must, however, also report any violations of Haaga-Helia's activities to Haaga-Helia's internal whistleblowing channel in the first instance. In certain cases, you can also submit a notification to the Chancellor of Justice's centralised external whistleblowing channel or directly to the competent authority.

You can submit a notification to Haaga-Helia's internal whistleblowing channel if you have observed a breach in the following areas:  

• public procurement with the exception of defence and security procurement
• financial services, products and markets
• prevention of money laundering and terrorist financing
• product safety and compliance
• traffic safety
• environmental protection
• radiation and nuclear safety
• food and feed safety and animal health and welfare
• public health within the meaning of Article 168 of the Treaty on the Functioning of the European Union
• consumer protection
• protection of privacy and personal data
• security of network and information systems.

For these, it is also required that the breach

• is punishable by law
• may result in an administrative fine or
• may seriously undermine the achievement of the general interest objectives of the legislation.

You can also report

• breaches of the rules governing the financial management or implementation of the European Union's expenditure or the collection of its revenue or resources
• breaches of the rules on the granting, use or recovery of subsidies or state aid
• breach of competition rules
• breaches of tax rules by companies and entities or arrangements to obtain tax advantages
• breaches of the law designed to protect consumers.

The Haaga-Helia internal whistleblowing channel is not intended to be used in situations such as disputes over payment of wages, working hours, copyright or other matters concerning your employment or working conditions. The whistleblowing channel is also not a general feedback or complaints channel.

As a whistleblower you may be protected if you have received information about a breach in the course of or in connection with your work. You may be

• employed or have already left your job or have just started looking for a job.
• self-employed
• a shareholder
• a member of the board of directors or supervisory board of a company or foundation, or a managing director
• a volunteer
• a trainee
• an employee of a company providing services to Haaga-Helia.

You may also be protected if you assist a whistleblower in the whistleblowing procedure or have contacts with the whistleblower and are at risk of retaliation because of your job or position. Such a situation may arise if, for example, you are a member of staff who has assisted with the whistleblowing, or a contract partner, colleague or relative of the whistleblower.

In addition, the provisions on protection also apply to a legal entity owned by the whistleblower or in which the whistleblower works, or with which the whistleblower is otherwise connected by virtue of his/her work, and who may be subject to retaliation because of his/her position.

The whistleblower protection provisions do not apply if you are, for example, a student or visiting researcher, unless one of the other conditions mentioned above is also met.

To benefit from the protection described herein, the notification must meet the general conditions for whistleblower protection. Whistleblower protection includes a prohibition on retaliation. This means that the employer or other organisation under whose management and control you work or with which you are otherwise associated must not retaliate against you for reporting the breach or prevent you from reporting it.

The prohibition of retaliation also applies if you have acted as an assistant to the whistleblower or are otherwise in contact with the whistleblower. Prohibited retaliation would include termination of employment, lay-off, rescission of contract or some other negative consequence or unfavourable treatment. However, the law is not intended to prevent the employer's normal right of direction.

When you submit a notification under the Whistleblower Protection Act, you may also disclose information that is subject to restrictions on disclosure (confidentiality) without penalty, if the disclosure is necessary to uncover the breach. However, this does not apply if the acquisition or obtaining of the information is punishable by law.

If the prohibited retaliation is found to have been used, you have the right to recompense or compensation for the financial damage caused.

Whistleblowing will be treated impartially and confidentially. Whistleblowing may only be processed by the persons designated for that purpose at Haaga-Helia, namely the Haaga-Helia lawyer and Administration Director. In the event of a potential conflict of interest, the whistleblowing may also be dealt with by the CFO. In addition, other persons or experts may need to be consulted in order to investigate the matter reported.

If you have given your name when whistleblowing, your identity will be protected. Those handling a notification are bound by confidentiality, which can only be waived in the circumstances specified in the Whistleblower Protection Act.

Once Haaga-Helia has received the notification, acknowledgement of receipt will be sent to you within seven days of receipt of the notification at the latest. A Haaga-Helia lawyer will then check whether the Whistleblower Protection Act applies to the notification and will investigate the matter described in the notification and its accuracy.

After investigating the matter, the Administration Director of Haaga-Helia (or, in the case of a conflict of interest, the CFO) will decide whether and what further action to take on the matter described in the notification. You will be informed of the action taken on your notification no later than three months after the date of transmission of the acknowledgement of receipt of the notification.

Once you have carefully read the general conditions for whistleblower protection, you can submit a notification by sending an encrypted e-mail using the following button:

Submit a notification

The notification is protected by the Securedmail service. Verbal notifications will not be accepted. In the notification, you must describe, among other things,

• the breach to which the notification relates
• how it occurred and why it may constitute a breach
• your position in relation to Haaga-Helia (e.g. employee, the employee of a service provider)
• who are the possible parties involved in the breach.

In order for the case to be processed, you must provide as much information as possible. You do not have to reveal your identity in the notification. Haaga-Helia will need your valid email address for any additional information and for any communication on the notification.

Intentionally providing false or incorrect information is punishable by law and can lead to liability for damages.

How to send a Securedmail message

• In the top field of the Securedmail screen, enter your email address at which will receive a confirmation request from the Securedmail server.
• Type your message and add any attachment(s).
• You can accept the password suggested for the message or put in a password of your own.
• The password will automatically be sent by SMS to the mobile phone of the person handling the notification at Haaga-Helia.
• Click on “Send”.
• From the Securedmail server, you will receive a confirmation request to your email address, which you will need to acknowledge by clicking on the link in the message. The message will only be sent to Haaga-Helia after this acknowledgement.

How to accept a Securedmail message

• You will be notified about the Securedmail message sent to you by your email inbox.
• Open the message and click on the link in the message.
• Open/save any attachments.

Please note that you will not be able to reopen the message on another device, nor will you be able to reopen it after 14 days. Even if you do open the message, it will be deleted from your Securedmail after 14 days. If you do not open the message, it will be deleted after 90 days.

In order to receive whistleblower protection, you must first submit a notification to Haaga-Helia's internal whistleblowing channel. The Office of the Chancellor of Justice serves as the centralised external whistleblowing channel for whistleblower protection. You can submit a notification to the centralised external whistleblowing channel if the three general conditions for whistleblower protection are met (see point 1) and one of the following conditions is met:

• You have not been given the opportunity to submit a notification through the internal whistleblowing channel.
• You have reasonable grounds to believe that the internal notification that you have sent has not been acted upon within the time limit or cannot be effectively addressed.
• You have reasonable grounds to believe that you are at risk of retaliation as a result of the notification.

The Office of the Chancellor of Justice will refer the notification to the competent authorities for investigation. For more information on the centralised whistleblowing channel, see website of the Office of the Chancellor of Justice.