Warning Procedures for Mimeta

The purpose of these warning procedures is to establish a clear and secure process for reporting reprehensible matters within our organisation and the programs mimeta are running. This contributes to integrity and transparency, strengthening our efforts towards sustainability and ethical conduct.

Who is this procedure for?
The procedure applies to all employees, including managers, permanent and temporary staff, consultants, and other collaborators like partners of Mimeta and their partners or grantees, and other participants involved in in realizing the programs of Mimeta.

Purpose of warning procedures:
The procedure aims to uncover any reprehensible matters within the organization and programs so that we can address the issue and prevent its recurrence. We treat all cases equally and handle them all seriously.

Definition of reprehensible matters:
Reprehensible matters may include violations of laws and regulations, ethical guidelines within the organization, or ethical norms widely accepted in society. This may involve matters posing a risk to life and health, climate or environmental risks, corruption or other financial crimes, abuse of authority, sexual harrassment, unsafe working conditions, or breaches of personal data security.

What is not considered reprehensible matters?'
Expressions related solely to an employee's own employment are generally not considered as warnings. Examples of an employee's own matters not covered by the warning rules:

Personal differences of opinion: Disagreements that do not violate the organisation's ethical guidelines or policies and do not negatively affect the work environment.
Ordinary work conflicts: Routine conflicts or dissatisfaction related to job tasks, working conditions, salary, or management, which should be resolved through regular HR channels or direct dialogue.
General dissatisfaction: Feelings of dissatisfaction not linked to specific actions that may be considered illegal or in violation of the organization's ethics.
Individual performance issues: Feelings of dissatisfaction not linked to specific actions that may be considered illegal or in violation of the organisation's ethics.
Personal dissatisfaction: Private or personal matters that do not affect the work situation or involve the organisation.

Guidelines of Mimeta that have relevance to the definition of reprehensible matters:

1. Anti-Corruption Guidelines

2. Code of Conduct

3. Gender Guidelines

4. Guidelines for Eligibility

5. Warning procedures

6. Financial Handbook

7. Guidelines for Risk Management

8. Ethical Guidelines.

9. Handbook for Internal Control of HES

See here for downloading the documentation!

The employee's right to report is established in the Norwegian Working Environment Act § 2 A-1. The Managing Director is responsible for ensuring that the warning procedures comply with legal requirements.

How to report:

Reporters can choose between:

Identified reporting: Submit a report through the reporting form (below) so that the case handlers have access to the reporter's email address.
Anonymous reporting: Reporters can also submit reports anonymously.
Direct reporting: Reports can be made directly to the nearest manager or other personnel in management.

What a report should include:

The reporting form (below) will guide you through the reporting, but a report should contain a factual, objective, and specific presentation of the possible reprehensible matter. The following information should be included.

What happened (violations of laws and regulations, breaches of ethical norms, or internal guidelines)?
Where did this happen?
When did this happen?
What is the scope?
Is there any evidence or documentation that can support the information about the reprehensible matter?

Anonymous Reporting:

Submitting a Report: When using the reporting form, reporters have the two options:

Email Identification: Reporters can choose to submit their reporting form with email identification.
Anonymous Reporting: Reporters can opt for anonymity. In this case, they define a username/psydonym (ID), which will be used for subsequent communication.

Follow-up Page: Within ten working days of submission, a dedicated page is opened for the reporter at www.mimeta.org/psydonym (where "psydonym" is the reporter's own defined ID). This page serves as a platform for further communication. The psydonym is also used as the password for access.

Commentary Process: Upon accessing the page, reporters can use the comments feature for dialogue. When prompted for identity, reporters enter their psydonym and select "Comment as Guest." Comments will be displayed under the psydonym.

Revealing Identity: If reporters wish to disclose their real identity at a later stage, they provide their actual name and email.

Lost psydonym: Reporters who lose their psydonym will not gain access to the case space.

Procedure for Receiving Reports:

Reports are handled by the case manager after delegation from the board. Reporters receive acknowledgment of receipt if contact information is provided. Anonymously submitted reports receive confirmation through the portal upon login.

Processing of Reports:

All reports are processed within ten days.
An initial assessment determines severity and scope.
Internal or external investigations may be initiated if necessary.
Discretion is maintained to protect involved parties' integrity.

Follow-up and Feedback: Reporters receive ongoing updates on the report's status. A final report summarizes findings and recommends actions.

Access to Cases: Only the Chair of Board and the one who responsibility of handeling is delegated to has access to case details stored in the system. The portal logs all activity for dispute resolution.

Reporter Protection: Strict policies against retaliation are enforced. Reporter identities are protected throughout the process unless disclosure is necessary.

Contradiction (to Object): Reported individuals have the right to present their version of the case and access report contents.

External Reporting: Reporters are encouraged to report internally first. If issues are staying unresolved, they can contact public authorities.

Reporting to External Entities:

Individuals who prefer to report suspected instances of corruption, funding of terrorisme or human rights violatins externally or who are not comfortable using internal reporting channels may report their concerns to the following external entities:
Relevant regulatory bodies or government agencies responsible for overseeing anti-corruption measures in Norwegian Foreign policy are the ministry that have outsourced the notifications service to the auditor EY. To get in contact, use: https://dh8342.customervoice360.com/uc/admin/6a9b/ospe.php?SES=a9d75207225e65f3623e7ae4ceeed953&syid=6052&sid=6053&act=start

This notification service is for all employees of the Ministry of Foreign Affairs, the foreign missions and everyone who is in contact with the Ministry and the foreign missions' grant recipients, other collaboration partners and suppliers. The service is a secure electronic notification solution and is operated by the investigation unit of the advisory and auditing company Ernst & Young AS (EY). You choose whether you want to report anonymously. If you provide your name and contact information, it enables further contact with you. It is often necessary to ask further questions about objectionable circumstances that are reported. It is possible to remain anonymous to the employer even if your contact information is known to EY's notification reception. If you choose to only provide your identity to EY, they will contact you to follow up on your notification.

Law enforcement authorities or anti-corruption agencies with jurisdiction over the matter in Norway is an entity called Økokrim. You can get in contact by using this channel: https://tips.politiet.no/web/.