Whistleblowing Policy Summary
Finora Bank has established a whistleblowing framework for the secure reporting, assessment and investigation of suspected infringements, misconduct and other serious matters affecting the public interest, regulatory compliance, sound governance or the Bank’s integrity.
The framework applies across Finora Bank, UAB, its Estonian branch and Finora Group AS, in accordance with applicable legal and regulatory requirements.
Who can report?
The whistleblowing framework is available to persons who become aware of relevant concerns through their professional, contractual or pre-contractual relationship with Finora, including:
- shareholders;
- members of the management bodies;
- employees;
- temporary employees and secondees;
- contractors and subcontractors;
- consultants;
- suppliers and service providers;
- trainees, interns and apprentices;
- volunteers;
- persons working under the supervision or direction of contractors, subcontractors or suppliers;
- persons involved in a pre-contractual or other business relationship with the Bank;
- clients and other third parties reporting concerns relating to the Bank’s activities.
What cases can be reported?
Reports may be made in relation to:
- legal and regulatory breaches;
- money laundering, terrorist financing and sanctions-related breaches;
- fraud, embezzlement and other financial wrongdoing;
- bribery, corruption and conflicts of interest;
- misuse or non-transparent use of funds or assets;
- breaches of internal rules, policies and procedures;
- significant internal control, governance or operational failures;
- concealment of infringements or obstruction of investigations;
- discriminatory conduct, abuse of authority, gross negligence or gross mismanagement;
- data protection, confidentiality or information security breaches;
- health, safety or environmental risks;
- misconduct affecting the financial interests of the European Union;
- competition law, state aid or corporate tax-related infringements;
- other serious matters affecting the public interest, the Bank’s integrity or financial stability.
How Finora handles whistleblowing cases?
All reports are handled through a controlled process designed to ensure timely assessment, appropriate escalation, documented investigation and, where necessary, remediation or reporting to competent authorities. Finora applies confidentiality safeguards in relation to the identity of the reporting person, the persons concerned and the information received, subject to applicable law and the requirements of a proper investigation; anonymous reports are accepted and assessed in accordance with the Policy, although follow-up may be limited where the reporting person cannot be contacted.
Protection against retaliation
Finora prohibits retaliation against persons who submit reports in good faith and on reasonable grounds, in accordance with applicable whistleblower protection requirements.
Good faith standard
The whistleblowing framework is intended for reports made honestly, responsibly and on reasonable grounds, where the reporting person believes that the information provided is true and relates to an actual or suspected infringement. Knowingly false reports do not qualify for protection and may result in liability under applicable law.
Scope limitation
The whistleblowing framework is not intended for routine personal, employment or contractual matters where another established internal procedure is available. Employees, candidates, contractors and other persons should use the relevant HR, complaint, disciplinary or contractual channels for such matters, unless the concern also involves a public interest dimension, systemic misconduct, serious wrongdoing, or an attempt to conceal an infringement.
Reporting channel
Reports may be submitted via the dedicated whistleblowing email: [email protected]