RareWine Group has implemented a whistleblower scheme that allows individuals to inform us anonymously of violations of the Group’s Code of Conduct. In the event of a breach, we may, among other things, issue a warning or demand repayment of a grant.
RareWine Group asks you to read the information below carefully before submitting your report.
You can make a report if you have information about a violation as described in RareWine Group's Whistleblower Policy.
The following groups of persons can thus report to the internal Whistleblowing unit of RareWine Group:
Employees
Self-employed professionals, e.g., self-employed professionals working with a RareWine Group company
Members of the Executive Board or the Board of Directors, etc.
Volunteers
Paid or unpaid trainees.
Persons working under the supervision and direction of contractors, subcontractors, and suppliers. This group of persons includes employees of a company with which a RareWine Group has entered into a contractual relationship.
Former employees
Applicants who report information about violations to which they have gained access during the hiring process or other pre-contractual negotiations. This group of individuals includes both individuals who are subsequently hired by RareWine Group and individuals who are not hired.
You can report information on
violations of EU law
serious offences, including bribery, forgery, hacking, eavesdropping, interception, recording conversations between others, theft, embezzlement, fraud, computer fraud, fraudulent misrepresentation and extortion
harassment, including sexual harassment, serious personal conflicts at work and serious harassment, for example due to racial or ethnic origin, gender, color, language, property, national or social origin, political or religious affiliation
Other serious matters
The internal whistleblower program in RareWine Group makes a case-by-case assessment of whether such serious matters are involved.
The whistleblower program cannot be used to report classified information falling within the limits of the Ministry of Justice's circular no. 10338 of December 17, 2014. Your report will be treated confidentially by trusted employees of the RareWine Group's dedicated Whistleblower Unit, who are, inter alia, authorized to work with reports and are subject to a special duty of confidentiality with regard to the information contained in the reports.
You cannot make your review anonymously using RareWine Group's internal system on the website. We respect and cherish your wish to remain anonymous. We must therefore inform you that if you wish to make an anonymous report, you should use an external whistleblower system where it is possible to remain anonymous. We therefore refer you to the external whistleblower scheme of the Danish Data Protection Agency https://whistleblower.dk/indberet.
In addition to the information, you have submitted to us, we may need to ask you additional questions in order to process your report in the best possible way.
Communication with you about your report in the Whistleblowing Portal will be discreet and fully anonymous to outsiders if you so wish. Via email, the Whistleblowing Unit will write to you directly if further documentation is needed or to keep you informed about the processing. You can add further information as and when needed.
Once you have submitted your report, you will generally receive a confirmation of your report within 7 days from the whistleblowing unit.
You can read more about the internal whistleblowing procedure in RareWine Group's whistleblowing policy.
In relation to the processing of your data by us, the GDPR gives you the following rights:
Right to request access to the data we process about you
Right to request rectification of inaccurate data
Right to request erasure of data and right to request restriction of processing of your data.
If you want to use your rights, you must provide and verify your identity so that we can find your data and make sure that it is not sent to the wrong recipients.
We are required by Article 13 of the GDPR to provide you with the following information when we receive information about you:
RareWine Group is the data controller - contact info
The purposes and legal basis for processing your personal data
Who has access to your information and to whom we disclose it
How long your personal data is kept
Your rights as a data subject
You can read more about our processing of your personal data and your rights under the Data Protection Regulation here: https://www.datatilsynet.dk/hvad-siger-reglerne/vejledning/de-registreredes-rettigheder-