Under the Whistleblower Protection Act (also known as the Whistleblower Act) regarding violations of European Union law, an internal reporting channel has been created at Metrosert AS for reporting violations of EU law. The internal reporting channel can be accessed via teavitaja@metrosert.ee.

What violations can be reported?

The reporting channel can be used to report violations or suspected violations occurring or suspected at Metrosert in the following areas related to Metrosert’s activities:

• Public procurement;
• Financial services, products, and markets, and the prevention of money laundering and terrorist financing;
• Product safety and compliance;
• Transport safety;
• Environmental protection;
• Radiation protection and nuclear safety;
• Public health;
• Consumer protection;
• Privacy and data protection, and the security of networks and information systems;
• Violations related to the internal market (competition and state aid violations, potential tax fraud related to the EU).

Knowingly submitting false information is prohibited. Reports are also welcome regarding violations of national law on relevant topics, but in such cases, Metrosert has no obligation to follow any investigation duty arising from specific legislation.

Who can report?

Whistleblowers can include all Metrosert employees, former employees, interns, job applicants, contractors, and employees of contractual partners.

When does protection apply?

A whistleblower is entitled to protection under the law if they have reasonable grounds to suspect that a violation covered by the law has occurred. To receive protection, the choice of the reporting channel must comply with the legal regulations.

Other reporting channels

In addition to the internal reporting channel, external reporting channels or public reporting can also be used.

External reporting channels can be used to report violations without prior use of the internal channel. However, public reporting is subject to the following conditions:

• The whistleblower has previously reported the violation via an external reporting channel, and the report was not processed according to the legal requirements;
• The violation presents an immediate or obvious risk of irreparable harm to the public interest;
• There is a reasonable suspicion that pressure measures will be applied in response to the external reporting;
• There is a reasonable suspicion that the violation will not be properly processed, or that the competent authority is connected to the violation.

Receipt and processing of reports

Upon receiving a report of a violation, Metrosert will send an acknowledgment of receipt to the whistleblower within seven days. Based on the report, Metrosert will initiate an internal investigation to determine the circumstances of the alleged violation. If necessary, additional information will be requested from the whistleblower.

If Metrosert is not competent to process the report, it will forward the report to the relevant authority.

Providing feedback

Metrosert will provide feedback to the whistleblower on the outcome of the investigation and any follow-up actions as soon as possible, but no later than three months after receiving the report.

The report will be retained for three years from the date the feedback is provided.

Ensuring confidentiality

Specific individuals are designated to manage the internal reporting channel, including receiving reports, processing them, and providing feedback, with the responsibility to ensure the confidentiality of the fact of reporting the violation.