WHISTLEBLOWING

One of the key goals at RDB is promoting a compliance culture allowing us to work in a safe and ethically correct organization. This includes bringing forward any potential breaches of the Code of Conduct or regulatory requirements.

Addressing wrongdoings is essential for the security and development of our company and is the responsibility of both staff members and external stakeholders. However, raising difficult matters openly is not everyone's cup of tea for various and valid reasons. Therefore, we have installed a whistleblowing program that provides you with different ways to report a breach, including the possibility to report anonymously.

We would like to give you some guidance for the proper use of these reporting channels.

Breaches of law or violations of our code of conduct like bribery and corruption, suspicions of money laundering and breaches of financial sanctions regimes, fraud and theft, conflicts of interest, violations of the securities supervision act, harassment at work, mobbing, discrimination or failure to protect personal data. 

Important: Please do not use this channel for standard customer complaints, but use our complaints management for this purpose.

You will help our investigators and shorten the duration of the investigation significantly by adhering to the following principles and providing relevant supporting materials. 

We kindly ask you to provide

• a clear and concise description of the issue (please avoid general statements such as "this is a fraud" and give as much details as possible to explain your perception; 
• (if available) copies of any relevant, lawfully obtained documents, such as emails, phone records, text messages, activity logs, meeting notes, pictures, letters or scans related to your report;
• (if applicable) lists of names and telephone numbers of other potential witnesses who can support your statement. 

We keep the whistleblowing process as simple as possible. Depending on the report, either a Compliance investigator or a Group Audit investigator will review your report within 48 hours.

The time to investigate a report will vary depending on the complexity of the case. During the investigation, you can always communicate with the investigator via the same channel you filed the report.

We use a platform provided by Whispli, an award-winning provider of whistleblowing tools, for anonymous reporting. Whispli was developed by a corporate whistleblower who uncovered a $ 20 million fraud at his company. 

Whispli protects your identity by providing the highest standards of data security and by making the entire process completely anonymous (background data like the user's IP address or document proprieties of uploaded files are not passed on to us). You have full control of what you submit.

We must all ensure prompt and consistent actions against violations of our Code of Conduct. However, in some situations it is difficult to know if a violation has occurred in the first place. You should keep in mind the following:

In order to reach the right solution, we must be as comprehensively informed as possible.

What specifically am I being asked to do? Does it seem unethical or improper?

This will enable you to focus on the specific question you are faced with and the alternatives you have. Use your judgment and common sense: If something seems unethical or improper, it probably is. If you are doubtful you can of course discuss the matter with your manager, if you feel comfortable with it. In many cases, he or she will be more knowledgeable about the issue and will appreciate being brought into the decision-making process.

In most situations, there is a shared responsibility. Are your colleagues informed? It may help to get others involved and discuss the problem.

You may report ethical violations in confidence and without fear of retaliation. If your situation requires that your identity is kept secret, your anonymity will be protected. Our top management does not permit retaliation of any kind against the party who reported potential ethical violations in good faith.

If you are unsure of what to do in any situation, please seek guidance from us – we’re happy to help!