• Introduction

    This policy aims to explain the purpose of whistleblowing and how to report via Thunderful’s whistleblowing portal. 

    Thunderful is committed to maintaining an honest, open, and transparent workplace. If there is a suspicion of current or past misconduct, it is essential to have the necessary resources in place to uncover it.

    The whistleblower channel provides an opportunity, in a work-related context, to report suspicions of misconduct that are in the public interest to be brought to light.

  • Whistleblowing

    Whistleblowing is the disclosure of information relating to suspected past, present, or likely future wrongdoing, example categories are as follows: 

    • Law and/or regulation violation 
    • Misbehaviour such as financial impropriety (e.g., fraud) 
    • Endangerment of someone’s health and safety 
    • Environmental crimes 
    • Serious forms of discrimination/harassment 

    Many issues should not be reported through the whistleblower channel as they do not constitute misconduct that is in the public interest to bring to light. Examples of matters that you should not report include:

    • Your own work situation, such as employment conditions (including salary) or working environment. 
    • Opinions and complaints about the actions or decisions of other employees or managers. 
    • Dissatisfaction or opinions about a management decision, such as changes in job responsibilities. 

    These concerns should instead be addressed with your manager, your People & Culture team or your manager’s superior.

    When making a report, it’s essential that, at the time, you had reasonable cause to believe the details of the misconduct you reported were accurate. Determining if there were valid reasons should be based on facts and context available to you when the report was made, as these form the basis for your belief in the misconduct’s truth. 

    You can report misconduct that occurs in a work-related context and is contrary to EU laws/regulations. If you suspect this, please refer to the scope of the Whistleblower Directive in Article 2 and Annex Part 1 for applicable laws and the Whistleblower Act Section 2. 

    Whistleblowing can be utilised by anyone, both internally and externally, who has or has had any form of interaction with Thunderful. When reporting a case, you are protected by the Whistleblower Act and therefore protected against reprisals or retaliation.

  • How to Raise a Concern

    Team members of Thunderful can first utilise internal reporting, either verbally or in writing, by contacting their manager. However, due to the sensitivity of the concern, another person might be more appropriate for reporting. Therefore, team members can also contact: 

    • Their local People & Culture team member 
    • The Executive, VP, or Director of their respective business are
    • Their Studio Head 
    • The CFO
    • The CEO

    A report under this paragraph is not a report within the whistleblowing channel.

  • How to Report

    Use our digital whistleblowing channel, which is always available here. Click the link, then under “Concern to report,” describe what has happened as thoroughly as possible. After reporting, you will receive a link; it is crucial to save this link, as you will not be able to access your report again without it. If you lose the link, you can submit a new report referring to the previous one. Within 7 days you will receive confirmation that we have received your report. You can communicate anonymously via the platform with the person handling your report and will receive feedback within three months on any measures planned or implemented due to the reporting. 

    Do not include sensitive personal information about individuals unless necessary. Sensitive personal data includes information about ethnic origin, political opinion, religious or philosophical beliefs, trade union membership, health, a person’s sexual life or sexual orientation, genetic data, and biometric data used to uniquely identify a person. 

    All reports classified as whistleblower case will be investigated according to the following:

    • Whistleblower cases will be handled confidentially.
    • No one who is involved or affected by the case will conduct the investigation.
    • The whistleblower function may contact the person who submitted the report if necessary.

    You can choose to disclose your identity or remain anonymous. Sometimes, the person handling your report may request you to disclose your identity at a later point, with strict confidentiality, to continue the investigation. 

    If you want to report verbally, you can request a meeting via Hailey HR’s whistleblowing channel. A verbal meeting can, with your consent, be recorded or documented in some way; you can request to access and approve this afterwards.

    We encourage you to initially report any malpractice internally. However, if you encounter obstacles or believe internal reporting is unsuitable, you may report the issue externally instead (or after an unsuccessful internal report). In such cases, please reach out to the relevant authorities or, if applicable, to EU institutions, agencies, or bodies.

     A list of Swedish authorities’ external whistleblower channels and their areas of responsibility can be found in the appendix to the Swedish Whistleblower Ordinance. More information on how to report is available on the respective competent authority’s website.

    European institutions that have also established external reporting channels include the European Commission, the European Anti-Fraud Office (OLAF), the European Maritime Safety Agency (EMSA), the European Union Aviation Safety Agency (EASA), the European Securities and Markets Authority (ESMA), and the European Medicines Agency (EMA).

  • Your Rights

    Retaliation and threats of retaliation are forbidden. We will keep your identity as a reporter confidential and restrict case access to only those necessary. Your identity will not be revealed without your approval, unless legally required, and we will ensure you are not subjected to retaliation. Protection from retaliation extends to your workplace contacts, including colleagues, relatives, and related entities. 

    As long as you had reasonable grounds to believe the misconduct was true and within the Whistleblower Act’s scope, you are protected from reprisals, even if identified. However, if acquiring or accessing the reported information was illegal, this protection does not apply. Protection against retaliation extends to legal proceedings, including: 

    • Defamation 
    • Copyright infringement 
    • Breach of confidentiality 
    • Breach of data protection rules 
    • Disclosure of trade secrets 
    • Claims for damages under private, public, or collective labour law 

    You will not be held liable for any consequences resulting from your reports or disclosures, provided you had reasonable grounds to believe that reporting or publishing the information was necessary to expose misconduct. Protection extends to publishing information if you have reported internally and externally without action within three months (or six months in justified cases). It also applies if there is an imminent public danger or risk of ineffective remedying of misconduct, such as evidence tampering. Note that this protection does not cover disclosures directly to the media under freedom of speech systems, though whistleblower and source protection may still apply.

  • Whistleblowing Function Responsible

    The following employees are responsible for whistleblowing reports 

    Linda Andersson
    Director of People & Culture Sweden
    linda.andersson@thunderfulgames.com 

    Kenneth Qvarfordt
    IT Manager
    kenneth.qvarfordt@thunderfulgames.com 

    Matilda Dahlin
    People & Culture Generalist
    matilda.dahlin@thunderfulgames.com 

    Sarah Griesche
    People & Culture Manager UK
    sarah.griesche@thunderfulgames.com 

    We prioritise protecting your personal information and comply with the General Data Protection Regulation (GDPR). Personal data irrelevant to the case will be deleted, and cases will be retained only as long as necessary, up to two years. For details, refer to the Thunderful privacy policy. 

    For technical questions about the Hailey HR Whistleblowing platform, please create a whistleblowing case or contact someone above.