Purpose of Our Whistleblower Scheme
Batteriretur is committed to ensuring legitimate waste flows and high-quality data and reporting to the authorities, so that end-of-life electrical and electronic products can gain new life through reuse and material recycling.
The purpose of the whistleblower scheme is to allow Batteriretur’s employees, partners, and other market actors to report irregularities—either anonymously or with known identity—related to the collection, storage, transport, and treatment of electronic waste. Financial crimes that are wholly or partly connected to the handling of electronic waste are also covered by the whistleblower scheme.
Matters not related to the handling of end-of-life electrical and electronic products will not be processed under the whistleblower scheme.
How Do You Report to Batteriretur’s Whistleblower Scheme?
Reports must be submitted in writing by email or letter to the whistleblower unit:
Attorney Peter Lambert
Amaliegade 31
1256 Copenhagen K
Email address: pl@lassenricard.dk
Reporting Companies That Do Not Fulfil Their Producer Responsibility (Freeriders)
Batteriretur’s whistleblower scheme does not provide an option to report companies that are subject to but do not comply with the producer responsibility for electrical and electronic products.
Can You Report Anonymously?
If you wish to remain anonymous, please be aware that when uploading or sending files—such as documents, videos, photos, etc.—or if you call or email, you may unintentionally disclose information that could reveal your identity.
In any case, you can inform the whistleblower unit that you wish to remain anonymous. The whistleblower unit is bound by attorney-client confidentiality and may not disclose any information you do not wish to be shared.
However, please note that a wish to remain anonymous may in some cases limit the handling of your case, particularly if the whistleblower unit needs to ask follow-up questions or request additional information.
How Are Reports Handled?
The whistleblower unit conducts an initial review of the report to determine whether it meets the criteria for further processing. If so, a thorough assessment will follow, including a decision on how the report should be handled—such as whether it should be referred to the relevant authorities.
To support the further handling of the case, it may be necessary to obtain additional information from the whistleblower. In that context, you may be asked to respond to further questions.
What Are Your Rights as a Whistleblower?
As a whistleblower, you have the right to be informed about the progress of the investigation and the outcome of the case, unless such information is subject to confidentiality rules.
If you have submitted a report in good faith and experience negative consequences as a result, you are encouraged to notify the whistleblower unit. Together with Batteriretur’s CEO and Chair of the Board, the unit will seek to remedy the situation.
Statistics and Overview of the Whistleblower Scheme
A log is maintained for the scheme, and Batteriretur publishes an annual report on its operation, observing the necessary confidentiality and anonymisation requirements.
Data Protection
In connection with the management of the whistleblower scheme, you consent to the processing of personal data. Due consideration is given to anonymity and any expressed wish to remain anonymous. The processing of personal data within the whistleblower scheme is subject to the rules set out in the General Data Protection Regulation (GDPR) and the Danish Data Protection Act.
Data Controllers:
The whistleblower unit, as well as Batteriretur’s CEO and Chair of the Board.
Purpose:
To investigate irregularities related to waste management and other serious matters.
Legal Basis:
Articles 6 and 8 of the General Data Protection Regulation.
Legitimate Interest:
Processing is necessary for the data controller or a third party to pursue a legitimate interest, namely to prevent and remedy irregularities related to waste management.
Recipients:
Recipients of personal data include the data controllers, relevant authorities, and other appropriate third parties.
Retention:
It is not always possible to determine precisely how long personal data processed within the whistleblower scheme will be stored.
Information relating to reports that fall outside the scope of the whistleblower scheme will generally be deleted one year after the case is closed. However, general and anonymised data will be retained for the purpose of preparing the annual whistleblower report.
Reports that fall within the scope of the whistleblower scheme and lead to further investigation will generally be retained for five years.
Your Rights:
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The right to access the data being processed.
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The right to have inaccurate data corrected or to have incomplete data completed.
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The right, in certain cases, to have data deleted before the general retention period expires.
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The right, in certain cases, to restrict the processing of personal data.
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The right, in certain cases, to object to otherwise lawful data processing.
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The right to data portability.
Complaints:
You can file a complaint about the processing of your personal data with the Danish Data Protection Agency: www.datatilsynet.dk
