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Complaints channel for whistleblowing and grievances

Finnfund’s complaints channel can be used to confidentially report a suspected misconduct, serious wrongdoing affecting people or our environmental and social responsibilities, or other breaches of the policies, codes or guidelines that steer Finnfund’s activities.

We strive to promote transparency and ethics in all our activities. We therefore encourage all our stakeholders to use our complaints channel to report any suspected misconduct, serious violations of environmental and social responsibility and human rights, or other violations of the policies, codes or guidelines governing Finnfund’s activities that may emerge in connection with the activities of Finnfund or companies financed by Finnfund, so that they can be properly addressed. This is also important for the development of our operations.

On this page, we explain what the complaints channel is about, how you can submit a report, and how Finnfund processes the reports it receives.

The contents of this page (please see the links below) and the reporting channel are available in the following languages: English, Finnish, French, Spanish, Portuguese, and Swahili. Messages in any language can be sent via the telephone service.

  • Ilmoita väärinkäytösepäilystä (Finnish)
  • Complaints channel for whistleblowing and grievances (français, pdf – CONTENT COMING SOON)
  • Complaints channel for whistleblowing and grievances (español, pdf – CONTENT COMING SOON)
  • Complaints channel for whistleblowing and grievances (português, pdf – CONTENT COMING SOON)
  • Complaints channel for whistleblowing and grievances (swahili, pdf – CONTENT COMING SOON)

What is the complaints channel based on?

The Finnfund complaints channel and related guidelines and procedures are based on the following:

  • The EU General Data Protection Regulation (EU 679/2016)
  • The EU Whistleblowing Directive (EU 2019/1937)
  • The Whistleblower Protection Act (1171/2022)
  • The Act on Preventing Money Laundering and Terrorist Financing (444/2017)
  • Finnfund principles for ethical conduct and responsibility, such as the UN Guiding Principles on Business and Human Rights (UNGP) mentioned in Finnfund’s human rights statement and Finland’s human rights-based approach (HRBA)

The scope of Finnfund’s complaints channel is more extensive than the scope specified for reporting channels in Finnish legislation. In addition to the protection of whistleblowers provided for in Finnish law, Finnfund strives in all instances to protect the privacy and safety of whistleblowers.

What is the complaints channel about?

Our complaints channel can be used with confidence to alert Finnfund about suspected misconduct, serious wrongdoing affecting people or our environmental and social responsibilities, or other breaches of the policies, codes or guidelines that steer Finnfund’s activities. As such, the complaints channel can be used to report violations of the principles set out in whistleblower protection legislation as well as of Finnfund’s own principles of responsibility and other policies.

By reporting, you can help Finnfund react early to possible misconducts and violations.

Finnfund also requires of its investees to establish and maintain whistleblowing channels that are accessible to all.

Please note that Finnfund also has a contact form for customer feedback and other ordinary communications, available here.

On what grounds can a report be submitted?

The whistleblower does not need to have proof of a misconduct or a violation before submitting a report, but they must have reasonable grounds to believe that the information in the report is accurate. All reports are to be submitted honestly and in good faith. The deliberate reporting of incorrect or malicious information is prohibited. Whistleblower who intentionally provides or discloses false information in a report, may be fined for violating the law on whistleblower protection.

How does the complaints channel work?

Anybody can send us a message, either anonymously or with their personal details included. The channel offers two primary reporting methods:

  • All suspected violations can be reported by sending an anonymous or confidential message in writing or as a voice message at the address https://report.whistleb.com/fi/finnfund.
  • Alternatively, the report can also be sent by post to Teollisen yhteistyön rahasto Oy (Finnfund), Complaint Team, PO Box 147, 00181 Helsinki, Finland.

If a Finnfund employee wants to report a suspected violation involving either Finnfund or one of its employees, we recommend that the matter be reported first and foremost to the employee’s immediate superior. If the Finnfund employee so wishes, or if the suspicion concerns his or her superior, the matter may also be reported to the superior’s superior or to the Finnfund human resources department: people-culture@finnfund.fi

If the whistleblower is an employee of a company financed by Finnfund or another stakeholder, we recommend that the report be made primarily through that company’s own reporting channels. Finnfund requires that the companies it finances have a whistleblowing channel for their own employees and external stakeholders. If the report concerns a company financed by Finnfund, the whistleblower may also choose to report the matter personally to a Finnfund employee, who will record the report and forward it as is to the investigation team for processing.

All received reports will be treated confidentially, regardless of the method of reporting.

Anonymous report

If the whistleblower wishes to remain anonymous, she/he can submit an anonymous report. The complaints channel is managed by the external service provider WhistleB. The complaints channel safeguards anonymity by removing metadata such as IP addresses that could reveal the identity of the whistleblower. The person submitting the report will also remain anonymous in any further discussions with the persons handling the case. All messages are encrypted.

It is good to be aware that anonymous reporting may hinder the investigation, which is why whistleblowers are encouraged to disclose their identity openly. In order for the reported suspected misconduct or violation to be investigated properly, the issue should be described in as much detail as possible in the report. It should also be noted that even if the whistleblower does not provide their name and contact details, their identity may still become revealed based on the facts presented during a more detailed investigation of the case.

IMPORTANT: Remember to keep your username and password

Once the report has been submitted to the complaints channel, the whistleblower will automatically receive a username and a password. This username and password will be required in the future to log in to the complaints channel, which is desirable and also necessary if the whistleblower wishes to engage in discussions, provide additional information, or hear about the results of the investigation at a later date. Providing additional information is often necessary for the processing of the case as well. It is therefore important that the whistleblower saves the usename and password and logs back into the channel to continue the discussion. The password cannot be reset. If the password is lost, the whistleblower may need to resubmit the report.

All received reports and their related communications are recorded in the complaints channel, which is accessible only to the Finnfund investigation team. All dialogue with the whistleblower shall take place using the means of communication chosen by the whistleblower. Correspondence by mail is only possible if the report includes the contact details of the whistleblower to which mail can be sent.

If the report has been submitted to Finnfund’s complaints channel, the whistleblower will receive confirmation of receipt within seven (7) days. This message can be read in the complaints channel. If the whistleblower has provided their email address, they will also receive a message by email. If the report has been sent by mail or delivered in person to a Finnfund employee, Finnfund will not, as a rule, send a separate acknowledgement of receipt.

Secondary channels

The above methods are the preferred ways to submit a report. Suspicions of misconduct related to the scope of application of the Whistleblower Protection Act may be reported secondarily to the competent authority via the external whistleblowing channel maintained by the Finnish Chancellor of Justice: How to make a report? | Chancellor of Justice.

Suspicions of misconduct that do not fall under the scope of the Whistleblower Protection Act mentioned above may be reported secondarily to the OECD National Contact Point in Finland: finland.tem@gov.fi.

The investigation team will inform the whistleblower no later than within three (3) months after sending the acknowledgment of receipt of the report whether the case will be investigated and what measures will be taken on the basis of the report.

During the investigation, the investigation team will ask further questions as necessary and discuss the case with the whistleblower using the channel chosen by the whistleblower. The results of the investigation will also be communicated to the whistleblower through the channel of their choice. If the report was submitted via the complaints channel, it is again important that the whistleblower saves their username and password and uses those to log back in to the channel, if they wish to continue the discussion and hear about the outcomes of the investigation.

If the outcome of the investigation may affect the rights, interests, or obligations of the subject of the report or other parties concerned, the investigation team shall, where possible, report the results of the investigation to them as well.

The following principles shall be observed in investigating the case:

  • All reports are taken seriously and treated with confidence and impartiality.
  • An investigation will be launched if there are reasonable grounds to suspect misconduct, serious violation of environmental and social responsibility or human rights, or another violation of the policies, guidelines, or instructions steering the activities of Finnfund that is more serious than general suspicion or displeasure.
  • The investigation is conducted by Finnfund’s investigation team. The investigation team may, on a case-by-case basis, make use of Finnfund’s own or external experts and share information with other financiers, however all the while ensuring that the principles of whistleblower protection, independence, and data protection are upheld. Persons who are the subject of the suspicion or who have connections to the suspected misconduct or violation will not participate in the investigation of the report.

No member of the investigation team or any other person involved in the investigation process will attempt to identify an anonymous whistleblower in any way.

(Note: In this context, the term whistleblowing refers to the reporting procedure set out in the EU Whistleblowing Directive and the Finnish Whistleblower Protection Act. The term grievance refers to the reporting procedure referred to in Finnfund’s human rights policy and principles of responsibility.)

How will the whistleblower be protected?

Anyone can report their suspicions without risk of later becoming a victim, being discriminated against, suffering retaliation, or being placed in a disadvantageous position. In practice, this means that the terms and conditions of employment relationship of a whistleblower who reports genuine suspicions or concerns in accordance with these guidelines will not be adversely affected, and the whistleblower will not be subject to any other negative consequences in terms of employment or contractual rights, or be otherwise placed in a disadvantageous position as a result of the report (known as the prohibition against retaliation).

Finnfund does not accept any threats or other forms of pressure or punishment directed at whistleblowers, human rights defenders or other stakeholders. The whistleblower will also be protected if they have, in order to safeguard the public interest, disclosed a business secret in their report or in connection with the disclosure of information relating to the report.

If the whistleblower discloses or reports information about a violation that is restricted or prohibited by agreement or regulation, the whistleblower will not be held liable unless obtaining the information is punishable under Finnish law. A further condition is that the whistleblower must have had reasonable grounds to believe at the time of reporting that the reporting or disclosure of the information was necessary to expose the violation.

Whistleblower protection is also granted to persons who assist the whistleblower in the reporting procedure and other persons who have links to the whistleblower and provide information on the case.

How are personal data stored?

Finnfund will retain the reports and the personal data contained therein, together with the investigation documents, in the whistleblower channel for five (5) years from the date of receipt of the report. If the retention of personal data relating to the report is still necessary for the purposes of a criminal investigation, pending legal proceedings, an official investigation, or to safeguard the rights of the whistleblower or the person who is the subject of the report, the necessity of further retention of the data will be reassessed no later than three (3) years after the previous review. The review will be recorded in the complaints channel as a register entry for the report in question.

Personal data that are clearly irrelevant to the processing of the report will be deleted without undue delay.

What are the rights of the data subject?

The processing of personal data of whistleblowers and persons object of the report (i.e data subjects) is regulated by the data protection legislation in force in Finland at any given time.

The data subject has the right to access their personal data, request rectification of their data, object to the processing of their data, request a restriction of the processing of their data, or lodge a complaint with the Finnish Data Protection Ombudsman in accordance with the data protection legislation applicable in Finland. The right of the data subject to access their personal data may be restricted if necessary to ensure the possibility to verify the truthfulness of the report or to protect the identity of the whistleblower. The data subject has the right to be informed of the reasons for the restriction and to request that the data be disclosed to the Data Protection Ombudsman in accordance with Finnish data protection legislation.

Data controller and data processor

The data controller is the Finnish Fund for Industrial Cooperation Ltd (Teollisen yhteistyön rahasto Oy), Business ID 0356880-6, Porkkalankatu 22 A, 00180 Helsinki, Finland. The controller is responsible for the personal data processed in the complaints channel. The processing of reports in accordance with these guidelines is based on Finnfund’s statutory obligations and legitimate interest as the data controller to prevent reputational risk and to support ethical business practices.

The data processor is WhistleB, Whistleblowing Center Ab (World Trade Centre, Klarabergsviadukten 70, SE-107 24 Stockholm, Sweden). The data processor is responsible for the provision of the complaints channel service, including the processing of encrypted data such as messages intended to expose misconduct. WhistleB or its subcontractors cannot decrypt and read encrypted messages.

The processing of personal data related to whistleblowing is described in more detail in the Finnfund complaints channel privacy notice, which can be found here: Finnfund Whistleblowing privacy notice (pdf)

Transfer of data outside the EU and EEA

The data will be stored within the European Union (EU). The transfer of personal data outside the EU and the European Economic Area (EEA) is generally prohibited, unless specific measures are taken to safeguard the transfer of data in accordance with currently valid regulations and authoritative guidelines.