As part of the efforts to enhance the overall governance and robustness of the benchmark the Swedish Financial Benchmark Facility adheres to a Whistleblowing Policy with the purpose of receiving, addressing, and managing complaints related to its activities and functioning, and to operations linked to the administration, determination, and publication of its benchmarks. These procedures enable individuals to raise or disclose concerns about malpractice within the Swedish Financial Benchmark Facility at an early stage. These procedures apply in all cases where there are genuine malpractice concerns regardless of where they may be and whether the information related to the malpractice is confidential or not.
Whistleblowing claims may be made by any individual, including users, customers, suppliers and employees of the Swedish Financial Benchmark Facility, Panel Banks or Calculation Agent. If an individual raises a genuine concern and is acting in good faith, even if it is later discovered that they are mistaken, under this policy they will not suffer any form of retribution as a result. This assurance will not be extended to an individual who maliciously raises a matter they know to be untrue or who is involved in any way in the malpractice.
Procedure for raising a concern
The Swedish Financial Benchmark Facility encourage all individuals to alert us, on an anonymous basis if necessary, to potentially suspicious or manipulative activity, or other issues that may affect the integrity of benchmark.
Should your claim not be directly related to suspicious or manipulative activity, or to issues that may affect the integrity of the benchmark, please use the complaints form instead.
Investigations and Management of Whistleblowing
The Swedish Financial Benchmark Facility will endeavor to finalise any whistleblowing investigation within 60 days of receipt of a claim. The Head of Risk and Compliance holds the primary responsibility for monitoring the communication channels by which individuals may submit whistleblowing claims. Whistleblowing claims received by the SFBF will be investigated and resolved in a timely and fair manner by personnel who are independent of any personnel who may be or may have been involved in the subject of the alleged malpractice.
A Whistleblowing Manager will be appointed to investigate the whistleblowing claim in accordance with the Whistleblowing Policy. The Whistleblowing Manager will investigate the whistleblowing claim in accordance with the the Whistleblowing Policy and will be bound by professional confidentiality when processing the claim with regard to relevant parties. The Whistleblowing Manager must be able to work with sufficient autonomy with respect to the SFBF. Upon appointment to the role of Whistleblowing Manager, the Whistleblowing Manager will provide acknowledgement to the whistleblower of receipt of their whistleblowing claim.
Upon the completion of the whistleblowing investigation the Whistleblowing Manager will compile a report and share with the governing bodies of SFBF for their consideration. Any actions required as a result of the decision of the SFBF governing bodies will be implemented as soon as practicable. When the remedial action, if any, has been implemented the Whistleblowing Manager will advise the whistleblower and any other relevant persons, of the outcome of the SFBF’s investigation into the whistleblowing claim.
All whistleblowing alerts and claims received will be addressed and resolved in accordance with relevant legislation. Every effort will be made to keep the reporting individual’s identity confidential, unless SFBF is obliged to, in the event of any subsequent judicial proceedings or in case of an investigation by regulatory and supervisory agencies, disclose the individuals identity. In order not to jeopardise the investigation into the alleged malpractice, the reporting individual will also be expected to keep the fact that they have raised a concern, the nature of the concern and the identity of those involved confidential.
Anonymous disclosures are very difficult to act upon as there may be little or no corroborated evidence to substantiate the allegations. Proper investigation may prove impossible if the investigator cannot obtain further information from the reporting individual, give them feed-back or ascertain whether their disclosure was made in good faith. In the event the claims made turn out to be false and made in bad faith, SFBF may take legal action or file a complaint with a regulatory or supervisory agency.
Alternative whistleblowing methods
As an alternative method to using the online whistleblow form individuals may report to us via email, phone or letter.
Swedish Financial Benchmark Facility
Box 7603, 103 94 Stockholm, Sweden
Report directly to the Head of Risk and Compliance on email@example.com
Report directly to the Managing Director, Catharina Hillström, on firstname.lastname@example.org