Acts in violation of Patria's Code of Conduct, even when done with the best of intentions, may cause significant long-term damage to Patria´s reputation and may lead to legal actions against the company and its Personnel. Patria is commitmented to support and protect employees who refuse to act unethically. Any member of Patria Personnel who violates the Code is subject to strict discipline, up to and including termination of employment or contract. Patria commits to supporting and protecting the employee or other person that refuse to act unethically, even when that might result in a loss of business.
The Code (or materials related to the Code) cannot possibly address every specific situation that Personnel will face in the complex business environment. In case of uncertainty, Patria Personnel are advised to discuss the matter with the nearest superior, the Human Resources Department, or to seek advice from the Patria Legal Department. Furthermore, all Personnel members are obligated to diligently report any compliance concerns or potential or suspected violations of this Code to their own superior or to the General Counsel. Channels for reporting are available in the company's officila languages, English and Finnish and they are
- an email address leading to the Chief Compliance Officer and
- Patria’s internal channel, enabling anonymous reporting.
- External stakeholders can contact Patria via the feedback link, also enabling anonymous reports.
In all instances, the rights and privacy of both the reporting person(s) and the one(s) accused of violations are adequately protected and assured. Patria will not tolerate any adverse employment action or retaliation against a person who raises a compliance concern. Any person who retaliates against another for raising a compliance concern in good faith will be subject to strict discipline, up to and including termination of employment.
Patria publishes statistics on reports in its Annual Report's Corporate Responsibility section annually.
All the reports from different channels are investigated according to a process described in Patria's Integrated Management System. Reports in general and related actions are reported to the Audit Committee regularily. In 2018 no serious misconducts or any cases including bribery or corruption were reported. Reports concerned issues falling within the responsibility of HR / management, such as managerial duties, recruitment and inappropriate behavior. Two of the reports came directly to the Chief Compliance Office, others via reporting system.
Patria does not report publicly details of the whistleblowing reports due to the GDPR.
Measuring the trust in the system
Patria measures its employees´ trust in the whistle-blowing and general reporting system and investigation process via a survey on “Possibility of serious misconducts in Patria” which is conducted every two years. The last survey was conducted in 2019 and included questions, such as
“Do you trust that it is safe to report unethical conduct in Patria?” 96.3% answered “yes” or “I have no opinion based on experience”. The follow up actions is to communicate more about the process and how safety is ensured. Also, a new Whistle Blowing system (with strict technical and procedural security measures) will be taken into use in the end of 2019.
“Do you trust that investigations related to unethical activity are conducted thoroughly and with integrity?” 95.5% answered “yes” or “I have no opinion based on experience”. The follow up action is to communicate more clearly about the investigation process. The new Whistle Blowing tool and process to be taken into use end of 2019 will also help ensure trust in these areas.