Policy for Feedback, Complaints and Whistleblowing

Policy for Feedback, Complaints and Whistleblowing is our Policy för Synpunkter, Klagomål och Visselblåsning in English. The policy describes how feedback, complaint and whistleblowing alarms can be reported within Erikshjälpen and how reported cases are handled.

Approved by the Board of Erikshjälpen 2025-05-22.

The policy applies to all of Erikshjälpen, that is, the second-hand business and the children’s rights organization in both Sweden and internationally.

Godkänd av Erikshjälpens styrelse 2025-05-22.

Policyn gäller för hela Erikshjälpen, det vill säga second hand-verksamheten och barnrättsorganisationen i såväl Sverige som internationellt.

Content

  1. Introduction and purpose
  2. Feedback
  3. Complaints
  4. Whistleblowing
  5. Complaints and whistleblowing regarding partner organisations
  6. Can I report anonymously?
  7. Principles for handling cases
  8. Procedure for handling complaints an whistleblowing matters
  9. Appeal handling of case
  10. External Reporting of Whistleblower

1. Introduction and purpose

This policy describes how feedback, complaints, and whistleblowing matters can be reported within ERIKS development partner and ERIKS Second Hand (hereafter ERIKS) and how reported cases are handled. Feedback, complaints, and whistleblowing represent three different levels of severity, where feedback can be both positive and negative, complaints aim to highlight deficiencies in the operations, and whistleblowing aims to alert about serious misconduct. These three types of cases will be described more in detail in chapters 2-4 of this policy.

ERIKS works to ensure that children’s rights are respected, protected, and fulfilled in Sweden and around the world. We have a zero-tolerance towards discrimination, all forms of abuse, sexual exploitation, and sexual harassment. We strive to be transparent and responsible in managing the donations we receive and work preventively regarding anti-corruption. Our approaches are described in our Child Safeguarding Policy, our Code of Conduct, and our Anti-corruption Policy.

ERIKS encourages the reporting of both improvement suggestions and misconducts in order to improve quality and address any deficiencies in our operations in Sweden and in our other programme countries. The purpose of this policy is to create a safe and open environment where transparent procedures ensure that all feedback, complaints, and whistleblowing matters are treated seriously, fairly, and confidentially, and with respect for the individuals involved.

Provisions on whistleblowing in this policy are based on the rights and obligations stipulated in the Swedish law (2021:890) on the protection of persons who report misconduct (the “Whistleblower Act”). The law is based on the EU Whistleblower Directive. When a whistleblowing matter occurs outside the EU, consideration will also be given to the specific legal requirements of that country.

2. Feedback

2.1. What is considered as feedback?

Feedback can concern anything within ERIKS´ operations, both positive and negative. It can include praise or suggestions for improvement.

2.2. Who can submit feedback?

Anyone who comes in contact with ERIKS can submit feedback, including participants such as children and parents/caregivers in our programmes.

2.3. How to submit feedback?

Feedback is submitted directly to the relevant department or operation. Contact information can be found on our website.

2.4. Who handles feedback?

Feedback is primarily handled within the relevant department or operation. If necessary, higher-level manager may be involved. When deemed relevant, the feedback can be handled as a complaint, as described below.

3. Complaints

3.4 What is considered a complaint?

A complaint is intended to draw attention to deficiencies in our operations and the operations of our partner organisations. It may concern deviations from, or suspicions of deviations from, agreements, guidelines, and policies. For example, a complaint may involve unethical behavior in any of our operations or among our partner organisations, but it is not considered to be as severe as a whistleblowing, i.e., it is not of such a nature that the public has an interest in it being exposed and stopped (see further information on whistleblowing in section 4 below).

Incidents related to an individual employee’s work environment are reported as an incident or work-related injury directly to the immediate manager.

Opinions regarding goods in our Second Hand stores are handled as feedback and submitted directly to the relevant store.

3.5 Who can file a complaint?

Anyone who comes in contact with ERIKS can make a complaint. This includes employees, volunteers, interns, partner organisations and their employees, donors, and customers. It also includes right-holders and their parents/caretakers in our programmes.

3.6 How can a complaint be reported?

Complaints are reported through a form on our website (erikshjalpen.se). To enable us to act on incoming complaints, it is preferable to specify which operation or store to which the case relates. A complaint can also be reported to complaints@eriksdevelopment.org or directly to a manager or employee at ERIKS. The recipient of the complaint can then enter the information into the website form.

We also ensure that we in our program initiatives have easily accessible ways for children and parents to file a complaint and that our international partner organisations have their own policies and systems for handling complaints. Reporting channels should be accessible and adapted to the local context and rights holders in our work.

If a partner organisation within our international programmes receives a complaint, the Regional Office can support the partner upon request. The complaint will then be reported through ERIKS complaint form.
Reporting regarding deviations from our Child Safeguarding Policy should be done promptly, if possible within 24 hours. Internationally, reporting is done according to what has been established in the partnership agreement.

3.7 Who receives the reported complaints?

Reported complaints are received by the relevant quality control group, based on the department or operation to which the case relates. There are quality control groups for different parts of the operations, including Second Hand, programme operations in Sweden, international programmes operations, and general matters relating to the organisation. The groups consist of department managers and, in some cases, controllers and/or coordinators. If necessary, other functions can be involved, such as Child Protection/Safeguarding Representatives, CFO, or HR manager. If the case concerns someone in the quality control group, the next higher-level manager or relevant board or external party will be involved.

4. Whistleblowing

The Swedish Act (2021:890) on the protection of persons who report misconduct (“whistleblower law”) describes the rights and obligations of whistleblowers. The law is based on the EU whistleblower directive. Whistleblowers must not be hindered from reporting misconduct and must be protected against retaliation. Below is a description of how ERIKS handles whistleblowing. ERIKS HR department can provide more details on the whistleblower law if needed.

4.1 What is considered a whistleblowing?

Whistleblowing is meant to alert an organisation of serious misconduct that is of such a nature that the public has an interest in it being exposed and stopped.

Whistleblowing should concern misconduct that has occurred or is most likely to occur in the organisation in which the reporting person is/has been/may become active, or in another organisation that the reporting person is or has been in contact with through their work. The whistleblower must have reasonable grounds to believe that the information about misconduct was true at the time of reporting in order to be covered by protection measures in relation to a whistleblower.

Whistleblower alerts may, for example, relate to:

  • Unethical behavior; such as violations of our code of conduct
  • Corruption and financial irregularities, such as bribery, unfair competition, money laundering, and fraud
  • Crimes related to health and safety, such as workplace safety violations or offenses
  • Environmental crimes; such as illegal handling of hazardous waste
  • Privacy breaches; such as improper use of personal data

 

Deviations related to the above categories that are not deemed to be so serious that the public has an interest in it being exposed and stopped can instead be reported as complaints (see section 3 above). Information that only concerns an individual employee’s own work or employment relationship is normally not covered by the whistleblower legislation and should instead be raised with the immediate manager, HR or the local trade union if there is one.

4.2 Who can report a whistleblowing matter?

A whistleblower is protected by whistleblower legislation if they, in a work-related context, have become aware of or obtained information about misconduct and report it. The whistleblower must also belong to one of the following categories:

  • Employees (including temporary staff and employees of partners/contractors/suppliers)
  • Job seekers
  • Self-employed individuals
  • Persons who are part of an organisation’s management or supervisory body
  • Interns
  • Volunteers

 

Persons who have belonged to any of the listed categories when they became aware of the information are also covered by protection measures in relation to a whistleblower.

In addition to the whistleblower, persons who assist the whistleblower in reporting, persons connected to the reporting person, and legal entities owned, worked for, or otherwise connected to the reporting person are also protected.

4.3 How to report whistleblowing matters?

There are four reporting channels for whistleblowing within ERIKS:

  1. Through a form on erikshjalpen.se
  2. Through email to visselblasning@erikshjalpen.se or whistleblowing@eriksdevelopment.org
  3. Through phone to the responsible recipient of reports
  4. Through a personal meeting with the responsible recipient of reports if requested via email or phone.

Form and contact information for the responsible recipients of reports can be found on erikshjalpen.se.

Whistleblowing forms guarantee anonymity if the whistleblower does not provide any personal information in the form.

Regardless of the channel you choose, your report should include the following information:

  • Your connection to ERIKS. If your case concerns a specific store, it is desirable to specify which store.
  • Describe the misconduct you want to report.
  • When did the misconduct occur? Is it still ongoing?
  • Who are the individuals involved?
  • Are there any documentation or other evidence?
  • Have you taken any other actions regarding the misconduct?
  • Are you available for additional questions to facilitate the investigation of the case?
  • Name and contact information of the informant (optional).

Reporting regarding deviations from our Child Safeguarding Policy should be done promptly, if possible, within 24 hours. Internationally, reporting is done according to what has been established in the partnership agreement. If a partner organisation within our international programmes wishes to do so, the Regional Office can support the reporting of whistleblowing cases to ERIKS.

4.4 Who are the responsible recipients of whistleblower reports?

ERIKS HR manager and a designated HR specialist are the responsible recipients of reports on misconduct. They are also the ones who receive reports through the whistleblowing form on erikshjalpen.se as well as the email address visselblasning@erikshjalpen.se and whistleblowing@eriksdevelopment.org.

If the HR manager or the designated HR specialist is directly involved in the reported misconduct, the report can also be made to the highest operational manager, ERIKS Secretary-General, or the Chairman of the Board. Contact information can be found on erikshjalpen.se and eriksdevelopment.org.

The designated recipients of reports have the mandate to handle and investigate incoming reports independently and autonomously. In order to investigate and address the misconduct, additional individuals may need to be involved, and access to any personal information will be limited to what each person needs to fulfil their duties. The person handling a whistleblower case must not unlawfully disclose information that could reveal the identity of the reporting person, or any other individual involved in the case.

5. Complaints and whistleblowing regarding partner organisations

ERIKS collaborates with local partner organisations to implement children’s rights initiatives. According to ERIKS’ Project Agreement, the partner organisation is committing to work to prevent, detect and identify any illegal action or misuse of funds.

ERIKS accepts complaints and whistleblowing regarding local partner organisations and their employees but also encourages partners to develop their own complaint handling systems to enhance accessibility and transparency in project areas. Reporting channels should be accessible and adapted to the local context and rights holders in our work.

6. Can I report anonymously?

When you report a complaint or whistleblowing matter through the form on our website, you can choose to remain anonymous. However, we encourage you to provide your name and contact information so that we can investigate the incident and address it properly, and you can receive feedback on the actions taken. Even when personal information is provided, it is handled confidentially, meaning that the information is only accessible to individuals who are authorized to access it.

7. Principles for handling cases:

When handling cases, we work according to these principles.

  • Accessibility – ERIKS has easily accessible ways to report misconduct. This also includes a complaint reporting system tailored for children.
  • Transparency – ERIKS strives for openness and transparency in all aspects of the organisation. This increases the possibility of scrutiny and ensures that any irregularities are addressed in a secure manner.
  • Accountability – ERIKS aims to have clarity in mandates and responsibilities, as well as structures and systems to trace mistakes and intentional errors. Individuals who have responsibilities within the organisation should be held accountable for their actions.
  • Confidentiality – The information in reported cases is only shared with individuals who are authorized to access it. Access to personal information is limited to what each person needs to fulfil their duties.
  • Security and protection – ERIKS places great importance on guaranteeing the security and protection of those who report misconduct or have been subjected to any irregularities related to our operations.
  • Non-retaliation – Those who raise complaints or report whistleblowing matters should not face any form of retaliation, reprisals, or negative consequences as a result of their reporting.
  • Objectivity – The persons handling cases strive to handle them professionally and conduct as objective investigations as possible.
  • Right to appeal – ERIKS offers the right to appeal when a case has not been handled as expected.

8. Procedure for handling complaints and whistleblowing matters

Below is a description of the procedure following an incoming case. In all steps, the principles outlined in section 7 are followed.

8.1 Reception

Cases reported through the website forms are directly entered into a case management system and assigned a category for the specific type of case. The case is given a reference number. Only authorized individuals have access to the specific categories. If the case is reported verbally, the reporter and recipient can jointly fill out the form.

This specifically applies to whistleblowing matters:

In the case of verbal whistleblower reports, the recipient should document the report. This can be done through a recording if the reporter consents to it, or by creating a written document. The reporting person should be given the opportunity to review, correct, and approve the written record through their signature. A case is created in the case management system where documentation is stored.

The recipient sends confirmation that the whistleblowing matter has been received within seven days of receiving it, unless the reporting person has waived confirmation or the recipient has reason to believe that a confirmation would reveal the person’s identity.

8.2. Investigation

The case is investigated by the designated recipients. Additional individuals may be involved, when necessary, but the number of individuals involved should always be kept to a minimum.

Whistleblowing matters are investigated to determine their accuracy.

All whistleblowing matters and complaints containing sensitive information, such as allegations of gross misconduct, corruption, sexual exploitation and abuse, harassment, and assault, are investigated with special discretion and protection for the affected individuals.

If it is determined that the investigation can better be handled by an external party – for example, due to conflicts of interest, credibility reasons, or the need for expertise – such a party will be engaged.

If the case involves a failure to comply with our Child Safeguarding Policy and if the case involves children, action should always be taken promptly. If necessary, ERIKS Child Protection/Safeguarding Representative may be involved in the investigation.

Serious matters are promptly reported to the Secretary General of ERIKS and/or the Executive Director of ERIKS Second Hand. They determine whether to inform the boards.

If the case is deemed to be serious enough to pose a risk of an organisational crisis, the crisis management group will be involved, and handling will be done according to the established crisis management plan.

8.3. Actions

The recipients will decide on any necessary actions based on the results of the investigation. If needed, other functions will be involved to carry out necessary actions. Even in this case, discretion is observed and personal data is protected.

If there is suspicion that a child is in danger, a report of concern should be made to Social Services in countries where this is possible. Further details can be found in the Guidelines for Child Safeguarding, appendix 2.

If the case involves a criminal offense, it should be reported to the nearest police authority. Before making a report, the immediate manager should be contacted.

The recipients will follow up to ensure that the decided actions are implemented.

8.4. Feedback

If the reporter has chosen not to remain anonymous, the recipients will ensure that the reporter receives feedback on their case, preferably on an ongoing basis throughout the process when possible.

In the case of whistleblowing, confirmation of receipt should be provided within 7 days. The actions taken and the reasons for them should be communicated to the whistleblower within 3 months if they can be reached and wish to receive feedback.

Regardless of the type of case, our goal is to provide feedback as soon as possible, but no later than within one month.

8.5. Reporting, Evaluation, Control and Deletion

All incoming cases that are deemed to be of high severity will be communicated to the management and the board. Reporting will be done in an anonymized format when appropriate.

Once a year, cases and actions will be compiled and reported to the management and, when appropriate, the board, also in an anonymized format. In conjunction with the compilation, an evaluation of the process for handling incoming cases will be conducted, and any identified improvements will be implemented.

To ensure that whistleblowing cases are properly handled by the designated recipients, a quarterly review is carried out by the Secretary General or the Executive Director, who reviews all cases received in the previous quarter and ensures that they have been handled correctly. The results of the review are reported to the Board as part of the reporting of the internal control plan.

Whistleblowing cases are deleted at the latest two years after the case is closed.

9. Appeal handling of case

If the reporter is not satisfied with the handling of a case, a new case can be logged through the same form on the website where the case reference number and the dissatisfaction can be addressed.

10. External Reporting of Whistleblower

In Sweden, the government has appointed several authorities that have external reporting channels on their websites that can be used if one wants to report a whistleblowing matter to an external party. The different authorities receive different types of whistleblowing reports, see the list of their areas of responsibility here:

List of authorities with responsibility according to the regulation 2021:949 – Swedish Work Environment Authority (av.se)

Internationally, the availability of external reporting channels may vary. If necessary, the relevant Regional Office can refer to the relevant party.

Publicerad: 27 augusti 2025

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