Contents

1. Introduction and purpose
2. Definition and approach
3. Implementation
4. Monitoring

1. Introduction and purpose

Erikshjälpen is a non-profit second-hand business and a child rights organisation that works to ensure that children's rights are respected, protected and fulfilled in Sweden and around the world. Corruption is always an obstacle to social and economic development. It also risks damaging Erikshjälpen's trust among those we work with in our interventions and in relation to private and institutional donors, partners and customers in our stores. Erikshjälpen therefore sees corruption as a serious risk that counteracts our vision of a changed world where children's dreams come to life.

Parts of Erikshjälpen's activities, both in Sweden and internationally, are carried out in environments and contexts with a relatively high risk of corruption, which requires specific measures and approaches. Countries with high inequality, weak democracy and conflicts often have a higher risk of corruption. Similarly, internal risks such as handling large sums of money, close and long-term relationships between colleagues and representatives of different parties, and weak internal accountability can promote corruption. There is also a risk of corruption in, for example, procurement, purchasing and business partnerships, which often take place in Sweden.

The purpose of this policy is to describe how Erikshjälpen defines and relates to corruption and how we work to counteract, detect and act on corruption.

Erikshjälpen's work with anti-corruption is based on our identity document "In the service of love" which establishes our core values. In addition, the following documents are also linked to our work on anti-corruption:

• Feedback, complaints and Whistle blowing policy
• Procurement policy
• Code of conduct
• Child safety and protection policy
• Staff and recruitment policy

This policy is valid for all parts of Erikshjälpen's activities, i.e. the children's rights organization and Erikshjälpen Second Hand, in Sweden and internationally, and applies to Erikshjälpen's staff, trainees, volunteers, elected representatives and consultants. The policy also applies via agreement to Erikshjälpen's international partner organizations.

2. definition and approach

Definition of

Erikshjälpen follows Sida's definition of corruption, which is the abuse of trust, power or position for improper gain. Corruption includes, among other things, bribery, embezzlement, extortion, conflict of interest, nepotism and other similar irregularities. It is defined as the use of a position of power to benefit oneself, a close associate or one's own interests. The gain can include both financial and other benefits. Corruption also refers to the failure to take action.

Approach

Erikshjälpens approach to corruption is based on Sida's anti-corruption rule, which means always prevent, never accept, always inform and always act. This should be applied in all situations even if it means delays in interventions or termination of partnerships.

Erikshjälpen's activities are subject to Swedish law. The Swedish laws and regulations are applied to Erikshjälpen's work abroad where local legislation and rules must also be followed and respected. However, local laws can never be used as an excuse for corrupt or unethical actions.

3. implementation

Always prevent

Erikshjälpen works at all levels to conduct risk assessments that include risks of corruption. Structures and systems within the organization must always be designed to minimize the risk of corruption while continuously discussing values and ethics. All employees, elected representatives and volunteers have a responsibility to prevent corruption and must be given training and support in how to do this.

Trust is also an important part of combating corruption. Erikshjälpen therefore works constantly to build trusting relationships with partners and to create a good and constructive dialog.

Never accept

Erikshjälpen's employees, trainees, elected officials, volunteers and consultants should never accept corruption or corrupt acts, whether in our own operations or in interventions that we support financially or in other ways. It is our shared responsibility to ensure that every aspect of our work is characterized by fairness, transparency and honesty. Never accepting corruption means not only complying with the law, but also acting on our values and setting an example of ethical behavior in all situations. At the slightest suspicion of an irregularity, it must be reported.

Always inform

Erikshjälpen's employees, trainees, elected representatives, volunteers and consultants are obliged to report suspected or discovered corruption via our function for complaints or Whistle blowing on our website. More reporting routes and responsibilities can be found in our Feedback, complaints and Whistle blowing policy.

If the operation is funded by Sida, the Swedish Mission Council (SMC) must be informed. If the operation has another institutional donor, the relevant party must be informed.

Always act

Erikshjälpen must always act on tips, warning signals and suspicions of corruption. The action must be taken with discretion and with respect for those involved. Erikshjälpen investigates all suspicions of corruption and appropriate measures are taken to deal with the specific case and prevent something similar from happening again. Internal and external reporters and whistleblowers are offered anonymity and other security measures if needed. The procedures for how a case is assessed are the same whether the information first comes to Erikshjälpen through our complaints and Whistle blowing function or otherwise. More information on the procedure for suspected corruption can be found on our website and in our Feedback, complaints and Whistle blowing policy

Transparency

Erikshjälpen always strives for openness and transparency in all parts of the organization's activities. This applies to policies, strategies, plans, decisions and reports. This enables insight into and scrutiny of the business, which can help to increase confidence in Erikshjälpen among employees, volunteers and elected officials as well as partners and other stakeholders.

Accountability

Erikshjälpen strives to have a clear mandate and division of responsibilities and to have structures and systems to track mistakes and deliberate errors. The people who have responsibility within the organization must be held accountable for their actions. An important part of this work is our complaints and Whistle blowing function, where suspected corruption can be reported. Our definition of complaints and Whistle blowing is described on our website and in our Feedback, complaints and Whistle blowing policy.

Participation

All relevant actors in Erikshjälpen's partnerships, including the intended target groups, must have ownership and influence over the planning, implementation and follow-up of our partnerships in order to be able to participate more easily in the work against corruption.

Partner organizations

Erikshjälpen encourages and supports our international and national partner organizations to have their own systems and procedures for working preventively with corruption and to detect and report corruption at the earliest possible stage. Our and our partners' agreements regulate how partner organizations and Erikshjälpen act in the event of suspected corruption.

Erikshjälpen strives to have an open and continuous dialogue with partners on the issue of corruption and on values and ethics. Support is provided to partner organizations that need to improve their internal control systems or implement other measures that prevent corruption.

Communication

This policy must be available on Erikshjälpen's intranet and website and be shared and added as an annex when signing an agreement with a partner organization. It should also be presented to new employees as well as elected officials, interns, volunteers and consultants within the organization.

4. Monitoring

Successful anti-corruption work requires continuous Monitoring and evaluation of the work. The Secretary General is ultimately responsible for the work on anti-corruption, that the policy is followed and that the work is evaluated. The policy is adopted by the board of the children's rights organization and revised when necessary.

All managers in both the children's rights organization and the second-hand business have a responsibility to ensure that anti-corruption work becomes an integral part of the work within their business. The immediate manager is also responsible for ensuring that employees are aware of the policy and the other documents that reflect Erikshjälpen's view of and work with corruption. All employees, in turn, have a responsibility to contribute to the realization of the policy's intentions and to work for anti-corruption.

The policy applies to all of Erikshjälpen, that is, the Second Hand business and the children's rights organization in both Sweden and internationally.

Contents

1. Introduction and purpose
2. Feedback
3. complaints
4. Whistle blowing
5. complaints and Whistle blowing regarding partner organizations
6. Can I report anonymously?
7. Principles for handling cases
8. Procedure for complaints and whistleblowing alerts
9. Appeal against the handling of a case
10. External reporting of whistleblowing alerts

1. Introduction and purpose

This policy describes how Feedback, complaints and whistleblower alarms can be reported within Erikshjälpen and how reported cases are handled. It applies to the whole of Erikshjälpen, i.e. the Second Hand activities and the children's rights organization in Sweden as well as internationally. Feedback can be positive or negative, complaints point to shortcomings in our activities while Whistle blowing warns of serious abuses. Chapters 2-4 describe these in more detail.

Erikshjälpen works to ensure that children's rights are respected, protected and fulfilled in Sweden and around the world. We have zero tolerance for discrimination, all forms of abuse, sexual exploitation and sexual harassment. We strive to be transparent and accountable in the management of the gifts we receive and work preventively on anti-corruption. Our approach is described in our Child Safety and Protection Policy, our Code of Conduct and our Anti-Corruption Policy, among others.

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

Whistle blowing is based on the rights and obligations stipulated in the Act (2021:890) on the protection of persons reporting wrongdoing (the "Whistleblowing Act"). The Act is based on the EU Whistleblowing Directive. When a whistleblowing case arises outside the EU, the specific legal requirements of that country will also be taken into account.

2. Feedback

2.1 What counts as a comment?

A comment can concern anything within Erikshjälpen's activities, both positive and negative. For example, it can be praise, feedback or suggestions for improvement.

2.2 Who can submit a comment?

Anyone who in any way comes into contact with Erikshjälpen or Erikshjälpen Second Hand can submit a comment, including participants and guardians who we meet in our program initiatives.

2.3 How to submit a comment?

A comment should be submitted directly to the organization concerned. Contact details are available on our website.

2.4 Who manages Feedback?

Feedback is primarily handled within the relevant activity. If necessary, senior managers can be involved. When deemed relevant, the comment can be handled as a complaints, see below.

3. complaints

3.1 What counts as a complaints?

A complaints is intended to draw our attention to shortcomings in our operations and those of our partners. It may concern deviations from, or suspected deviations from, agreements, guidelines and policies.

A complaints may, for example, concern unethical behavior in one of our businesses or with our partners, but it is not considered to fall within the scope of Whistle blowing, i.e. it is not of such a nature that the public has an interest in it being discovered and stopped (see further what applies to Whistle blowing in section 4 below).

Incidents concerning an individual employee's work environment are instead reported as an incident or an occupational injury via the intranet or directly to the immediate manager.

Opinions about in-store products are instead handled as comments and submitted directly to the store in question.

3.2 Who can lodge a complaints?

Anyone who in any way comes into contact with Erikshjälpen or Erikshjälpen Second Hand can make a complaints. For example, it can be employees, volunteers, trainees, partners and their employees, donors and customers. It can also be participants and guardians that we meet in our interventions.

3.3 How to report a complaints?

complaints are reported via forms on Erikshjälpen's website. In order for us to be able to act on incoming complaints , it is desirable to state which business or store the case concerns. It is also possible to report a complaints to complaints@erikshjalpen.se or directly to a manager or employee at Erikshjälpen or Erikshjälpen Second Hand. The person receiving the complaint can then enter the information in the form.

We also ensure that in our interventions we have easily accessible ways for participants and guardians to make complaints and that our international partner organizations have their own policies and systems for complaint handling. Reporting channels should be easily accessible and adapted to the local context and legal bearer of our work.

If a partner organization within our international program activities receives a complaints , the regional office can support the partner if possible. The complaint will then be reported through Erikshjälpen's complaints form.

Reporting of deviations from our child safety and protection policy should be done promptly, if possible within 24 hours. Internationally, reporting is done as defined in the partner agreement.

3.4 Who receives the complaints reported?

Reported complaints are sent to the relevant quality control group, based on which activity the case concerns. There are quality control groups for different parts of the business, including second hand, program activities in Sweden, program activities internationally and Erikshjälpen in general. The groups consist of operational managers and in some cases controllers and/or coordinators. If necessary, other functions can be involved, e.g. child protection officer, safety officer, financial manager or HR manager. If the case concerns someone in the quality control group, the next higher manager is involved, or the relevant board or external party.

4. Whistle blowing

The Act (2021:890) on the protection of persons reporting wrongdoing (the "Whistleblowers Act") describes the rights and obligations of whistleblowers. The Act is based on the EU Whistleblower Directive. Whistleblowers must not be prevented from reporting wrongdoing and must be protected from retaliation. Below is a description of how Erikshjälpen and Erikshjälpen Second Hand handle whistleblower alarms. Erikshjälpen's HR department can provide more details on the whistleblower law if needed.

4.1 What counts as Whistle blowing?

Whistle blowing is used to draw an organization's attention to serious wrongdoing that is of such a nature that the public has an interest in its detection and stopping.

The whistleblowing should concern wrongdoings that have occurred or are highly likely to occur in the activity in which the whistleblower is/has been/may become active or in another activity with which the whistleblower is or has been in contact through his/her work.

The whistleblower must have had reasonable grounds to believe that the information about the misconduct was true at the time of reporting in order to be covered by whistleblower protection.

For example, whistleblower alarms can be messy:

• Unethical conduct; for example, breaches of our Code of Conduct
• Corruption and financial irregularities; for example, bribery, unfair competition, money laundering and fraud
• Crimes related to health and safety; for example, health and safety crimes
• Environmental crime; for example, illegal handling of hazardous waste
• Privacy breaches; for example, misuse of personal data

Deviations linked to the above categories but which are not deemed to be so serious that the public has an interest in them being discovered and stopped can instead be reported as complaints (see section 3 above). Information that only concerns an individual employee's own working or employment relationship is not normally covered by the Whistleblowing Act but should instead be raised with the immediate manager or HR or the union.

4.2 Who can blow the whistle?

A whistleblower is protected by the Whistleblowing Act if he or she, in a work-related context, has become aware of or obtained information about wrongdoing and reports it. The whistleblower must also belong to one of the following categories of persons:

• workers (including agency staff and staff of contractors/suppliers/partners)
• job seekers
• self-employed
• persons who are members of the management or supervisory body of an organization
• trainees
• volunteers

Persons who belonged to one of the listed categories of persons and then received the information are also covered by whistleblowing protection.

In addition to the whistleblower, persons who assist the whistleblower in reporting, persons associated with the reporting person, and legal persons that the reporting person owns, works for or otherwise has a work-related connection to are also protected.

4.3 How to report a whistleblowing alert?

There are four reporting channels for whistleblower alarms internally within Erikshjälpen/ErikshjälpenErikshjälpen Second Hand:

1. Via form on erikshjälpen.se
2. Via email to visselblasning@erikshjalpen.se or to the responsible report recipient
3. By telephone to the responsible report recipient
4. Via personal meeting with the responsible report recipient if requested by email or phone

Forms and contact details for the responsible report recipients are available at erikshjalpen.se
Whistle blowing forms guarantee anonymity if the whistleblower does not provide any personal data in the form.

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

• Your connection to Erikshjälpen. If your case concerns a specific store, it is desirable that you indicate which store it concerns.
• Describe the misconduct you want to report.
• When did the abuse take place? Is it still going on?
• Who or what people are involved?
• Is there any documentation or other evidence?
• Have you taken any other measures in response to the misconduct?
• Are you available for additional questions to facilitate the investigation of the case?
• Name and contact details of the data provider (optional).

Reporting of deviations from our child safety and protection policy should be done promptly, if possible within 24 hours. In international programming, reporting is done according to what is established in the partner agreement. If a partner organization in our international program activities so wishes, the regional office can, if possible, support the reporting of whistleblower alarms to Erikshjälpen.

4.4 Who are the responsible recipients of whistleblowing reports?

Erikshjälpen's HR manager and a designated HR specialist are responsible for receiving reports of misconduct in accordance with Chapter 5, Section 5 of the Whistleblower Act and are also the ones who receive alarms via forms on erikshjalpen.se and the email address visselblasning@erikshjalpen.se.

If the HR manager or designated HR specialist is directly linked to what is being reported, reporting can also be made to the highest operational manager, Erikshjälpens Secretary-General, or to the Chairman of the Board. Contact details can be found at erikshjalpen.se.

The designated report recipients are mandated to independently and autonomously handle and investigate reports received. In order to investigate and remedy the misconduct, more people may need to be involved, access to any personal data will then be limited to what each person needs to fulfill their duties. The person handling a whistleblowing case must not unauthorizedly disclose any information that may reveal the identity of the reporting person or of any other individual involved in the case.

5. complaints and Whistle blowing regarding partner organizations

Erikshjälpen cooperates with local partner organizations to implement initiatives for children's rights. According to Erikshjälpen's intervention agreement, the partner organization undertakes to work to prevent, detect and identify any illegal or inappropriate activities or misuse of funds.

Erikshjälpen receives complaints and Whistle blowing regarding local partner organizations and their employees, but also encourages partner organizations to develop their own systems to handle this to increase accessibility and transparency in the operations. Reporting channels should be accessible and adapted to the local context and participants in the operations.

In order for participants to make a complaints , partner organizations are expected, as a minimum, to provide information on the names and contact details of the intervention management and other leaders in the partner organization. If the partner organization has a system for handling complaints and Whistle blowing, it is expected that the system includes the interventions supported by Erikshjälpen.

6. Can I report anonymously?

When you report a complaints or a Whistle blowing via the form on our website, you can choose to remain anonymous. However, we encourage you to provide your name and contact details so that we can investigate the incident and address it properly, and so that you can receive feedback on what has been done. Even when personal data is provided, it is treated confidentially, i.e. the information is only accessible to the persons authorized to access it.

7. Principles for handling cases

We follow these principles when handling cases:

• Accessibility - Erikshjälpen has easily accessible ways for reporting abuse. This also includes complaint reporting that is adapted for children.
• Transparency - Erikshjälpen strives for openness and transparency in all parts of the organization's operations. This increases the possibility of scrutiny and that any irregularities are addressed in a safe way.
• Accountability - Erikshjälpen strives to have a clear mandate and division of responsibilities and to have structures and systems to track mistakes and deliberate errors. The people who have responsibility within the organization must be accountable for their actions.
• Confidentiality - the information in reported cases is shared only with those persons authorized to access it. Access to personal data is limited to what is necessary for each person to carry out their duties.
• Safety and protection - Erikshjälpen attaches great importance to ensuring the safety and protection of anyone who reports misconduct or anyone who has been subjected to any irregularity linked to our activities.
• Non-retaliation - those who raise complaints or whistleblowing alarms should not suffer any type of retaliation, reprisals or negative consequences from their reporting.
• Objectivity - case handlers strive to handle cases professionally and to conduct investigations as objectively as possible.
• Right to appeal - Erikshjälpen offers the right to appeal when the case is not handled as expected.

8 Procedure for complaints and whistleblowing alerts

The procedure followed for incoming cases is described below. The principles set out in section 7 are followed at all stages.

8.1 Reception

The cases reported via the forms enter directly into a case management system, and are assigned a category for the specific case type. The case is given a reference number. Only authorized persons have access to the specific categories. If the case is communicated orally, the reporter and the recipient can fill in the form together.

This applies specifically to Whistle blowing:
In the case of an oral whistleblowing alert, the recipient must document the report. This can be done through a recording if the reporter agrees to it, or alternatively by drawing up a protocol. The reporting person must be given the opportunity to check, correct and approve by signature an established protocol. A case is created in the case management system where documentation is saved.

The recipient sends an acknowledgement of receipt of the whistleblowing report within seven days of receipt, unless the reporting person has declined acknowledgement or the recipient has reason to believe that acknowledgement would reveal the identity of the person.

8.2 Investigation

The case is investigated by the designated recipients. More people can be involved when necessary, but the number involved should always be kept to a few.

Whistleblower alerts are investigated to determine their accuracy.

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

If the investigation is deemed to be better handled by an external party - for example for reasons of conflict of interest, credibility or if expert knowledge is needed - such a party will be engaged.

If the case concerns a lack of compliance with our policy on child safety and protection and the involvement of children, action must always be taken promptly. If necessary, Erikshjälpen's child protection officer may participate in the investigation.

When serious cases are received, the Secretary-General of Erikshjälpen and/or the Executive Director of Erikshjälpen Second Hand Hand are informed as soon as possible. They then make an assessment of whether the boards or part of the boards should be informed.

If the matter is considered to be so serious that there is a risk of an organizational crisis, the crisis management group is involved and management takes place according to the established crisis management plan.

8.3 Measures

The recipient will decide on what action, if any, to take in response to the findings of the investigation. If necessary, other functions will be involved in order to implement the necessary measures. Again, with due discretion and protection of personal data involved in the case.

If there is a suspicion that a child is being abused, it may be necessary to report the concern to the Social Services, see further in Child Safety and Protection, Appendix 2 - Guidelines.

If the case involves a breach of the law, this should be reported to the nearest police authority. Before reporting, the nearest supervisor or manager should be contacted.

Beneficiaries regularly follow up on the implementation of agreed measures.

8.4 Feedback

If the reporter has not chosen to remain anonymous, the recipient ensures that the reporter receives feedback regarding his or her case, preferably continuously throughout the process whenever possible.
In the case of Whistle blowing , confirmation of receipt must be made within 7 days. The measures and reasons for these must then be communicated back to the whistleblower within 3 months if they can be reached and wish to receive feedback.
Regardless of the type of case, however, our internal goal is to provide feedback as soon as possible, but within one month at the latest.

8.5 Reporting, evaluation, accountability and disposal

All cases received that, after investigation, are deemed to be of a high level of seriousness will be shared with management and the Board. Reporting is done in an anonymized format where appropriate.

Once a year, cases and actions will be compiled and reported to management and, where appropriate, the Board, also in anonymized format. In connection with the compilation, an evaluation of the process for handling incoming cases is also made and any identified improvements are implemented.

To ensure that whistleblowing alerts are handled correctly by the designated recipients, an accountability review is carried out every quarter, where Secretary-General or the Executive Director reviews all alerts 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 against the handling of a case

If the reporter is not satisfied with the handling of a case, he/she can log a new case via the same form on the website, indicate the case reference number and describe his/her dissatisfaction.

10. External reporting of whistleblowing alerts

In Sweden, the government has designated a number of competent authorities that have so-called external reporting channels on their websites that can be used if you want to blow the whistle to an external party. The different authorities receive different types of whistleblowing, see the list of their areas of responsibility here:
List of authorities with responsibility according to area of responsibility under Regulation 2021:949 - Arbetsmiljöverket (av.se)

Internationally, external reporting channels may differ. If necessary, the relevant regional office can refer to the relevant party.