A whistleblower is a natural person who reports information about an alleged violation that may harm the public interest if the person believes the information to be genuine and the information was obtained in the course of performance of their job duties at the Company or in the course of entering into a legal relationship with the Company relating to the performance of their job duties or provision of services to the Company.

A whistleblower may raise an alarm about possible infringements that may harm the public interest, in particular about: corruption, fraud, tax evasion, public health risks, food safety risks, construction safety risks, environmental safety risks, occupational safety risks, public order risks, human rights violations, public procurement violations, financial and capital market offences, competition law violations.

Deliberately giving false information or reporting only detriment to personal interests is not considered whistleblowing.

How can a whistleblower report a violation?

A whistleblower can submit information about a possible violation (hereinafter — a Submission) using a reporting form and sends it:
• to the e-mail address: trauksmescelejs@cewood.com;
• by mail to Galdusalas 1, Jaunlaicenes pagasts, Alūksnes novads, LV-4336, including a reference “Whistleblower report”;
• the staff responsible for whistleblowing — Production Manager Mārtiņš Dulamanis or Human Resources Manager Sandra Cukermane-Apine;
• Board Member Ingars Ūdris, if the Submission is made in respect of either of the staff members in charge of whistleblowing.
If the whistleblower makes the Submission to the responsible person orally, the person in charge shall, in the presence of the whistleblower, put the report in writing using the reporting form.


What happens next?

  • The person in charge registers the whistleblowers’ reports in the Register of Whistleblower Reports.
  • Upon receipt of a submission, the person in charge shall promptly, but not later than within seven days, assess its prima facie compliance with the signs of whistleblowing laid down in the Whistleblowing Law and take a decision on its recognition as a whistleblower report. The person in charge shall inform the whistleblower about the decision within three days from the date of the decision.
  • If the submission does not fall within the competence of the Company, the person in charge shall, within ten days, forward it to the competent authority for consideration, while informing the whistleblower about it in writing.
  • If the submission is not classed as a whistleblower report, but the submitter states that they wish to receive a reply on substance, the responsible person shall make a note that the submission was originally submitted as a whistleblower report but was not deemed as such and shall forward it to the committee for further consideration.
  • The responsible person shall anonymize personal data or any other information revealing the identity of the whistleblower or the identity of the natural person or legal entity on which the whistleblower has reported and the anonymized whistleblower report.
  • A whistleblower’s report is examined on substance by a committee consisting of not less than three persons as established by an order of a member of Board of Directors of the Company.
  • The persons involved in receiving, recording and reviewing the whistleblower’s report ensures whistleblower’s safety (their identity is not disclosed) by reporting the person referred to in the whistleblower’s report about the processing of his data. Personal data, including the whistleblower’s name and contact details, contained in a whistleblower report are subject to special protection. This information is known only to the persons who need it for the processing and review of the report and for personal safeguarding. The whistleblower’s personal data are processed and stored in compliance with applicable personal data protection rules. At the same time, the whistleblower’s personal data may not be disclosed without a valid reason and without the whistleblower’s consent to persons who are not involved in the process of receiving and reviewing of the report and safeguarding of the whistleblower.
  • When reviewing a whistleblower’s report, the committee may request and receive information and explanations necessary for its examination.
  • If, during the review of the whistleblower’s report, a violation is found which does not fall within the Company’s competence, the committee promptly forwards the whistleblower’s report to the competent authority for review, informing the whistleblower about it in writing.
  • If the whistleblower wishes to report the same violation to the competent authority earlier than within two months, they may do so without losing the right to protection.
  • The committee reports to a member of the Company’s Board of Directors about the results of its review of the whistleblower’s report. If a violation is found, a member of the Company’s Board of Directors takes the necessary actions to impose liability in accordance with the laws and regulations.
  • The person in charge informs the whistleblower of the progress of the review of the whistleblower’s report no later than within two months.
  • The company ensures that information on any violations found is published to ensure compliance with legal requirements.
  • The published information includes data about the nature and type of the violation, the outcome of the violation proceedings, and the concerned public interests. When publishing information, risks must be assessed to ensure that the whistleblower’s identity is protected.
  • The company performs regular inspections and reviews to ensure effectiveness of the whistleblowing system and its compliance with the latest legislation, and to identify and eliminate potential deficiencies.