Whistleblower Policy

Last updated: 2022-07-15

At Avalanche Studios Group, we strive to create a supportive and respectful work environment where we look out for each other and follow all applicable laws. If you see something that you think is wrong, we want to know about it to make it right. One of the ways to do this is through the “whistleblowing system”, which is implemented in accordance with applicable legislation. 

We believe that the whistleblowing system outlined in this policy is essential to detecting and taking action against work-related misconduct. If you bring a claim forward, we pledge to investigate it fully to ensure a safe and inclusive workplace exists for all of us. Should we find anything inappropriate, we take immediate action.

This policy outlines when you should speak up and report misconduct to our Whistleblower Unit, the protection of whistleblowers, the internal reporting process, and how we will support you. 

This policy is available on our internal HR Site and Avalanche Studios Group’s external website. 

What’s the definition of a whistleblower?

A whistleblower is someone associated with Avalanche Studios Group reporting severe misconduct. In short, all people associated with Avalanche Studios Group can be whistleblowers. It doesn’t matter if you’re an employee, intern, contractor, board member, or job applicant. 

Making a whistleblower report

You can make a whistleblower report about severe suspected or confirmed misconduct cases within Avalanche Studios Group. We encourage you to report any other misconduct cases to your manager, HR manager or by using Winningtemp. We do not tolerate any form of retaliation against employees for making good faith reports. By good faith report we mean a report of severe misconduct which the person making the report has reasonable cause to believe is true.

Examples of reportable misconduct:

  • Work environment crime, such as severe cases of discrimination or harassment
  • Financial crime, such as corruption, tax fraud, and money laundering
  • Severe instances of personal data breaches

Examples of non-reportable misconduct:

  • Personal grievances
  • Sense of unfair treatment in terms of salary or promotion
  • Claims or complaints regarding products or services

If you are unsure whether an act of misconduct is reportable or not, we recommend that you report it. Coming forward is the right thing to do, and our Whistleblower Unit carefully reviews all reports.

The Whistleblower Unit investigates all concerns and is assigned by the company management to be independent and autonomous. The Whistleblower Unit is authorized to:

  • Receive reports and have contact with employees who have reported a concern
  • Initiate an investigation and involve parties relevant to the matter
  • Ensure a follow-up with the employee 

The Whistleblower Unit representatives are:

How do I file a whistleblower report? 

There are a number of different ways you can report your concerns. You can talk to the Whistleblower Unit directly or send an email or letter. If you’re more comfortable filing a report anonymously, you can use Winningtemp or talk with someone outside Avalanche Studios Group using external whistleblowing channels. 

Winningtemp

To submit a report, log in to Winningtemp and click on the “Whistleblow” button at the top. 

A representative from the Whistleblower Unit will review the report and get back to you. Please note that Winningtemp is only available to employees and interns.

Reach out to the Whistleblower Unit

You can always contact any member of the Whistleblower Unit. You can reach them here:

If you’re in Stockholm, you can also meet over a personal meeting that may be recorded with your consent. 

E-mail

Send an email ([email protected]) to the Whistleblowing Unit, use the subject: Whistleblower Report. 

Letter 

Send a letter to: 

Fatalist Development AB

BOX 112 38 

100 61 Stockholm

Sweden

Mark the letter with “Whistleblower Unit – Confidential”. 

Please note that if you provide us with contact details, we’ll be able to get back to you directly for further information as we investigate your concern. 

IMPORTANT: If you reach out to the Whistleblower Unit through Winningtemp, you don’t need to include any contact information as they can communicate with you directly and anonymously. Please include your contact details if you use any other channels and would like the Whistleblower Unit to get back to you.

External whistleblowing channels

It’s only with knowledge of misconduct that we can improve as a company, but If you feel more comfortable talking to someone outside of Avalanche Studios Group, you can file a report via external reporting channels to the relevant authorities. For example, the Information Commissioner's Office or the Swedish Authority for Privacy Protection is relevant when reporting privacy concerns. If you are unsure and need guidance on which authority to turn to, we recommend contacting your labor union or:

Sweden: Swedish Work Environment Authority, the supervisory authority in Sweden.  

New York: The Office of the Attorney General

Liverpool: The Advisory, Conciliation and Arbitration Service (ACAS) 

What to include in a whistleblower report? 

You should include the following in your whistleblower report: 

  • What is your concern? 
  • What happened? 
  • Where did it happen? 
  • When did it happen? 
  • Have you taken any other action concerning this case? 

In the report, you should not include any sensitive information from a privacy standpoint unless it is relevant to the case, including details on someone's health, sexual orientation, or political or religious beliefs.

When will the Whistleblower Unit get back to me?

If you make a report via phone or a personal meeting, you will immediately get confirmation that the report has been received. If you make the report via Winningtemp, email, or letter, you will receive confirmation of receipt of the report as soon as possible and no later than seven days after your submission. You will also receive a follow-up from the Whistleblower Unit within three months of submission.

In case of an emergency or imminent danger to someone’s life or health, you should always call the emergency number in your country. 

Sweden: 112

New York: 911

Liverpool: 999

Anonymity and Non-Retaliation

The Whistleblower Unit is not allowed to disclose information that may reveal your identity or any other individuals appearing in the report. If you're using Winningtemp, you’re always anonymous. However, there are exceptions to this to take appropriate action. Examples include handing over the report to HR, company management, or law enforcement. 

We do not tolerate any form of retaliation against anyone who files a report in good faith. An employee who is not knowingly misrepresenting facts in a whistleblowing report is protected by law against any form of retaliation for making the report. Retaliatory conduct can take many different forms, including suspension, dismissal or demotion, or other unfair treatment. If you suspect that someone is retaliating against you, we encourage you to contact your manager, HR manager, or Whistleblower Unit.

Investigation

What happens when I make a report? 

First, only the Whistleblower Unit has access to the reports, including those made through Winningtemp. All reports are carefully reviewed to determine the appropriate course of action, including:

  • Documenting all activities and the investigation.
  • Confirm that the report has been received within seven days of receipt.
  • Determine if the report should be handled by the Whistleblower Unit, be handed over to HR, or not be further investigated (see below).
  • If the next step is to conduct an investigation, it should always be kept confidential to the greatest extent possible. 
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  • At the end of an investigation, the Whistleblower Unit will take the actions it sees as necessary, which may lead to the decision to hand over the report to HR, the company management, or other parts of the company. 
  • Any actual or suspected breaches of the law may be reported to the relevant law enforcement agencies.

In some cases, reports will not be further investigated for reasons including: 

  • The report doesn’t follow the guidelines established in this document.
  • The report was not made in good faith. 
  • An investigation has already been made or is ongoing regarding the reported matter.

Note: The Whistleblower Unit will inform you of their decision if there’s a way for them to contact you, either through Winningtemp or the contact details you’ve provided.

Questions?

Please reach out to the Whistleblower Unit if you have any questions or any of the individual members:

About Personal Data in Whistleblowing Reports

Last updated: 2022-07-15

Personal data is any and all information relating to an identified or identifiable natural person. When we process personal data about you, we do so in accordance with applicable privacy laws.

Data Controller

Fatalist Development AB (dba Avalanche Studios Group) is the data controller for any personal data submitted or otherwise collected in connection with a whistleblower report.

Purpose of the Processing of Personal Data

Any data collected in relation to a whistleblower report will only be processed for the purpose of reviewing and investigating reported matters.

Collecting Personal Data

In addition to any data submitted by the one making the report, we may, during the investigation of the case, collect further information related to the person submitting the report, any person specified in a report, and any third party involved in investigating facts of wrongdoing and misconduct.

Sharing Personal Data

Personal data in relation to a whistleblower report may be shared with external parties assisting in the investigation of a case, law enforcement agencies, and other authorities when required.

Retention of Personal Data

Personal data included in a whistleblower report and any related investigative material is deleted upon completion of the investigation.

Legal Basis

The legal basis for processing personal information concerning a whistleblower report is 1) compliance with a legal obligation and 2) performance of a task carried out in the public interest.

Your Rights

You may exercise your rights under applicable privacy laws, including the right of access, right of rectification, and right to object to processing personal data. These rights may be limited under certain circumstances, for example when exercising these rights would significantly obstruct the investigation.

Winningtemp AB is our data processor concerning any personal data submitted through Winningtemp.