Whistleblowing Policy v. 1.3

Whistleblowing Policy

 

SalMar Tenet

We care!

CSRD Reference

S1 - Own Workforce | S2 – Workers in the Value Chain | S3 – Affected Communities | S4 - Consumers and End-Users 

Purpose

SalMar is committed to transparency, accountability, and fairness. This policy ensures that employees and external parties can safely report concerns, wrongdoing, or breaches of ethical standards without fear of retaliation. 

Scope

This policy applies to all SalMar employees, contractors, suppliers, customers and any external party wishing to report concerns related to SalMar’s operations, workplace environment, or ethical conduct. 

 

Governance and Accountability

Roles and Responsibilities

The Board of Directors holds ultimate responsibility for whistleblowing governance. The Director of Human Resource Management oversees all reports and ensures appropriate remediation actions are taken. Cases revealing systemic issues are escalated to senior management for evaluation and corrective action. 

Management is responsible for investigating reports promptly and fairly and implementing corrective measures. Employees are encouraged to report concerns and are protected against reprisals. HSE representatives and trade unions participate in case handling to ensure fairness and compliance with established protocols. 

Monitoring and Reporting

SalMar operates an independent whistleblowing channel managed by a third-party, available 24/7 via SalMar’s website and intranet in local languages and English. Reports can be submitted anonymously or with full identification. All cases are handled confidentially and documented in SalMar’s management system. Annual disclosures include the number of reports received and actions taken. 

 

Strategic Framework and Targets

SalMar’s strategy is to maintain a trusted whistleblowing system that encourages reporting of workplace grievances, unethical behaviour, or unfair treatment. The company commits to zero tolerance for retaliation and ensures all employees receive training on whistleblowing procedures and protection. 

The following sections outline the Group’s most material impacts, risks and opportunities, along with strategic targets established.  

Impacts

Human rights impacts, incidents or complaints | Human rights commitments  

Despite SalMar’s strong humanrights commitments, incidents and concerns may still arise. In a diverse workforce, there is a risk of misunderstandings, unequal treatment, or potential breaches of ethical standards, all of which can negatively affect employees’ wellbeing and trust. 

SalMar works actively to uphold human rights and ensure equal opportunities across all roles. A strong culture of transparency and accountability supports early detection of concerns and fosters a safe environment for raising issues without fear of retaliation. This contributes to a workplace characterised by dignity, fairness and respect. 

Risks

Neglecting diversity concerns  

SalMar employs a culturally diverse workforce, and failure to recognise and manage differences in backgrounds, languages and expectations can weaken collaboration and harm the work environment. Overlooking diversity concerns may reduce employee satisfaction, contribute to conflict or miscommunication, and lead to higher turnover, directly affecting productivity and operational performance. Unaddressed concerns may escalate or cause harm to employees and the organisation, while poor handling can undermine trust in the reporting system and discourage employees from raising issues in the future. 

Opportunity

Reliable protection of whistleblowers 

Ensuring reliable protection of whistleblowers strengthens a culture where employees feel safe to report concerns or breaches of guidelines. This supports early detection of misconduct, contributes to continuous improvement, and promotes a healthy and transparent working environment. 

Targets

SalMar enforces zero tolerance for retaliation against whistleblowers. All reports must be investigated promptly, and remedial actions implemented before cases are closed. The company commits to annual reporting on whistleblowing activity and continuous improvement of the system. 

 

Operational Measures

Reports from the whistleblowing channel are handled confidentially, with closing meetings to ensure satisfactory resolution. For issues related to human rights, discrimination, or systemic concerns, investigations involve HR or external parties to ensure fairness. All employees receive necessary training on whistleblowing procedures.