Whistleblowing Policy

Tele2 is committed to ethical business conduct at the highest level. We have a zero-tolerance policy when it comes to wrongdoing. Through our Code of Conduct we vow to take appropriate action when wrongdoing happens, and we ask our Business Partners to do the same.

For us to act, we first need to know of any wrongdoing. We therefore promote a culture where anyone within or outside Tele2 feels safe and is encouraged to act and report any wrongdoing related to our operations. This is approach actively supported by our CEO and the Board of Directors.

Tele2’s Whistleblowing Policy is an essential part of this commitment. It ensures that anyone working for or with Tele2 can report any wrongdoing. This includes workers employed directly or indirectly by Tele2, as well as others interacting with Tele2 (e.g. Business Partners, customers, shareholders, and other stakeholders). It also provides protection to any individual making a report of potential misconduct. In short, the Whistleblowing Policy:

• shields whistleblowers from retaliation;
• establishes requirements to safeguard confidentiality and anonymity;
• protects the reasonable interests of those accused;
• arranges the processing of personal data and data protection in the context of the policy;
• establishes procedures for reporting and for the handling of reports; and
• determines the governance of the policy.

The Whistleblowing Policy has been in place for all Tele2 operations since 2010 and it was updated in 2014, 2019 and in 2022. The full Whistleblowing Policy can be found in our Policies and Reports section. Links to relevant other policies, such as the Code of Conduct and the Anti-Corruption Policy can be found there as well.

Channels to report wrongdoing

We have implemented low-threshold possibilities for reporting any wrongdoing related to Tele2. All whistleblowing channels are designed, set up and operated in a way that ensures the confidentiality of the whistleblower.

Reports are received by Tele2’s Director Group Security, who work under supervision of, and with the support from the EVP Corporate Affairs and the Audit Committee of the Board or with respect to the Baltics, by the persons mentioned below. Reporting can be done either anonymously, confidentially, or openly and through different methods:

• Reporting to a manager, who will be responsible for escalating the report.
• Sending an email to report.violation@tele2.com which is directed to the Chairperson of the Tele2 Audit Committee and the Tele2 Whistle Blower Function. 
• Sending a letter to the following address (the letter will be forwarded to the Chairperson of the Audit Committee):

Tele2 Whistle Blower 
Att. EVP Corporate Affairs
Box 62
SE-164 94 Kista
Sweden 

• Making a call to +46 701 620 062, where your call will be answered by the Tele2 Whistle Blower Function.
• Requesting a meeting directly with the person designated to receive reports.
• As an alternative to the above, for matters related to:
  • Estonia you can also contact Head of Legal and Business Security Taivo Kendla via email tokendla@tele2.com or phone at +37 250 160 21
  • Latvia you can also contact Security Manager Martins Melnis via email martins.melnis@tele2.com or phone +37 126 446 691; and for
  • Lithuania you can also contact Legal & Regulatory Department Manager Edvinas Krasauskas via email edvinas.krasauskas@tele2.com or phone at +37 066 800 417

Reporting and Governance

Tele2 is committed to transparency in all of its Sustainability areas. We take care to report relevant information to our stakeholders, and balance the value of transparency with the requirements of confidentiality. Therefore, we report on an aggregated basis for all Tele2 subsidiaries, and only on relevant numbers. No information on the nature of individual cases is made available.

Members of the Leadership Team and (Audit Committee of) the Board of are informed ad-hoc of ongoing or concluded investigations when their importance requires this. Furthermore, they receive regular reports, at least quarterly, on the functioning of Whistleblowing in Tele2.

Number of reports

Since 2016, we have received 44 reports through the whistleblowing channels. Those reports have led to 39 internally performed investigations. As a result of those investigations, 26 disciplinary or other actions have been taken. (Last updated: September 2023)

Processing of personal data

The legal basis for processing personal data in a whistleblowing report is to fulfil Tele2’s legal obligation as an employer under the "Lag (2021:890) om skydd för personer som rapporterar om missförhållanden", i.e "The law on protection for individuals reporting on misconduct".

The purpose of the processing is to process personal data by a few specially authorized persons only in the extent that is necessary to follow up a whistleblowing report. 

The personal data is processed when 

• Receiving a report; and
• Contacting the whistle-blower; and
• Investigating the correctness of the report.

Tele2 processes personal data included in the report and data recorded during the investigation of the report. When processing data relating to employees under the Whistleblowing Policy, Tele2’s Employee Privacy Policy is applied.

The whistle-blower investigations will be stored in a dedicated and secure storage area. Records relating to reports made under the Whistleblowing Policy are stored for a maximum of two (2) years from the finalization of the investigation. Tele2 will not share personal data that was processed under the Whistleblowing Policy with third parties, except for notifying (a suspicion of) a crime to the relevant enforcement authorities.