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Whistleblowing policy

Acting ethically and taking measures to prevent irregularities is an important part of SEB Life International’s culture, we therefore have process for reporting irregularities.

If you, as an employee or any other party affected by our business discover potential or actual breaches of regulatory or internal requirements, unethical or unlawful behaviour, you should report your observations.

  • You may report anonymously.
  • You may report verbally or by writing to the authorised recipient.
  • You may request a physical meeting with the authorised recipient.
  • You may file a report during or outside working hours.

Report unethical or illegal behaviour

If you have a legitimate concern about relevant wrongdoing in the workplace we encourage whistleblowing. We will not take any measures against anyone having filed a whistleblowing report, either at the time the report is made, or subsequently.

Personal grievances that only effect the reporting person in a personal level are not protected by the Act and should be reported to HR. Such matters may be protected under general employment law.

You should not investigate your concerns yourself or try to prove if the concern is well-founded. As soon as you have a genuinely held concern, report it. Any employee knowingly or maliciously raising a concern they know to be untrue may face disciplinary action.

If a person is told not to report a concern, including by a person in authority, the person should not agree to remain silent and if they raise a concern, they will be within the full protections under the legislation.

Processing of personal data related to handling of a report shall be in compliance with the GDPR and any complementary Irish law or regulation. Personal data may only be processed for the purpose of handling of the Whistleblowing report. Only persons that have been designated to receive Whistleblowing reports may have access to personal data processed in a report. Personal data which are not relevant for the handling of a specific report shall not be collected or, if accidentally collected, shall be deleted without undue delay.

  • Criminal offences like fraud, money laundering, bribery, and corruption
  • Failure to comply with a legal or regulatory obligation
  • Actual or potential conflicts of interest
  • Accounting misstatement
  • Inaccurate, misleading, or fraudulent reporting of key risks
  • Price fixing, market abuse, or insider trading
  • Concealing or destroying evidence of wrongdoing
  • Behaviour that harms or is likely to harm SEB LI’s reputation or financial well-being.
  • Acknowledgement of your report will be sent within 7 days.
  • An initial assessment is conducted by the authorised recipient, including seeking further information from the reporting person if required, as to whether there is prima facie evidence that a relevant wrongdoing may have occurred. A decision will be communicated to the reporting person. If you have filed a report, the information provided may be shared with the SEB Group for the purpose of investigation, unless you have objected to the sharing of information.
  • Diligent follow-up is conducted by the authorised recipient.
  • Feedback on actions taken or planned to be taken will be issued no later than 3 months after the acknowledgement date.
  • Further feedback will be issued every 3 months if the case is complex, and the issue is still unresolved.
  • Any penalisation that causes disadvantage to a reporting person is prohibited.
  • Penalisation includes dismissal and also any other form of unfair treatment, such as suspension, reduction in wages or hours, demotion, and transfer of duties as well as intimidation and harassment.
  • Penalising a reporting person is a criminal offence and reporting persons are protected from any civil or criminal liability for reporting confidential information, provided it is done so in accordance with the law.
  • Non-disclosure agreements cannot be used to prevent a person reporting a wrongdoing.
  • Employers and regulators must keep the identity of the reporting person confidential.

Internal reporting

Concerns may be reported via the following channels.

Our Whistleblowing service

The anonymous reporting service ‘WhistleB’, used by SEB Life International, meet high security requirements regarding data security and protection of the reporter’s identity.

WhistleB

Phone

+353 (1) 487 0700

Address

Bloodstone Building, Sir John Rogerson’s Quay, Dublin 2, D02 KF24

External reporting

Concerns may be reported via the following channels.

Central Bank of Ireland

Phone

1800 130 014
Calls are answered Monday to Friday 9:30am – 5:00pm.

E-mail

confidential@centralbank.ie

Address

Protected Disclosures Desk
Central Bank of Ireland
PO Box 559
Dublin 1

Protected Disclosures Commissioner

Phone

+353 (1) 639 56 50
Opening hours Monday to Friday 9:15 am – 5:00 pm.

E-mail

disclosures@opdc.ie

Address

Office of the Protected Disclosures Commissioner
6 Earlsfort Terrace
Dublin 2, D02 W773

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