At Alba Tankers, we are committed to conducting our business with honesty, integrity, and professionalism. We expect all employees, managers, contractors, and partners to adhere to the highest standards of ethical behavior and to comply with our Code of Conduct. While we strive to maintain strong internal controls and a responsible corporate culture, we recognize that risks of illegal, unethical, or irresponsible conduct cannot be eliminated entirely. A culture of openness, accountability, and early reporting is a key part of preventing and addressing such risks.
This policy is established in accordance with the Danish Act on Protection of Whistleblowers (Whistleblowerloven) and the EU Whistleblowing Directive (2019/1937), which set the requirements for internal reporting channels, confidentiality, and protections against retaliation. The purpose of this policy is to ensure a safe and lawful way to report serious concerns. It is therefore intended only for reporting suspected serious wrongdoing, not for day-to-day operational matters, personal employment matters, routine issues, or general dissatisfaction.
Such matters must be instead reported through the appropriate company processes, including:
This policy is designed to:
This policy applies to all individuals who work with or for Alba Tankers, including:
These groups are protected under the Danish Whistleblower Act.
3.1 Governance – compliance committee
Alba Tankers has established a compliance committee, consisting of Jan Eghøj (Group CEO), Khartik Selvakumar (HSEQ Manager & DPA), and Sisse Mai (Chairman of the Member) which has overall responsibility for and oversees the effective functioning of the whistleblowing framework as well as review actions taken in response to reported concerns.
3.2 Operational responsibility
Day-to-day responsibility is assigned to the compliance officer (Håkan Kalmerlind, COO at Alba Tankers) who must ensure:
3.3 Review of the policy
The Compliance Committee reviews this policy as required by legal or organizational changes.
3.4 Responsibility of staff
All individuals are responsible for using Alba Tankers’ whistleblowing channels appropriately and in good faith.
4.1 Whistleblowing means reporting information related to serious misconduct, wrongdoing, or significant risks solely. Examples include, but are not limited to:
4.2 Whistleblower definition
A whistleblower is any person who reports such information in good faith through the appropriate channels.
4.3 Not personal HR matters
This policy does not apply to personal employment matters (e.g., disagreements with management, performance issues, salary matters). If you are an employee of Alba Tankers, we ask you to consider or reconsider addressing your concerns with your nearest superior, Mette Munk Jensen (people & culture coordinator at Alba Tankers), Håkan Kalmerlind (COO and compliance officer), or Jan Eghøj (group CEO at Alba Tankers).
4.4 Mixed concerns
If a concern includes both personal matters and one or more of the whistleblowing categories listed above, the compliance officer will determine the appropriate process.
5.1 Initial reporting
In many cases, concerns can be raised directly with your manager or with the people & culture coordinator, either verbally or in writing.
5.2 Safe reporting channels
If the matter is serious, sensitive, or you do not feel comfortable raising it through normal channels, you may report through Alba Tankers’ secure whistleblowing channels:
Email: whistleblower@albatankers.com
Whistleblower form (anonymous or non-anonymous): Whistleblower form
Postal mail:
Alba Tankers ApS
Att: Compliance Officer
Tagholm 15
DK-9400 Nørresundby
Denmark
All reports will be handled confidentially and promptly, regardless of the reporting channel used.
To support an effective investigation, please provide as much detail as possible, including, but not limited to:
Providing detailed information enhances the ability to investigate thoroughly.
You may choose to report anonymously. The whistleblowing system is designed to allow anonymous reporting in accordance with Danish law. Open reporting is encouraged where possible, as anonymity may limit our ability to investigate fully. If your identity becomes known during the investigation, Alba Tankers will take all reasonable steps to protect it. Your identity will only be disclosed:
Confidentiality also applies to any individuals mentioned in the report (“affected persons”), in accordance with the Danish Whistleblower Act.
Records related to the report will be stored securely and deleted when no longer necessary, typically within 90 days after the case is closed.
9.1 No retaliation
Alba Tankers strictly prohibits retaliation against anyone who raises concerns in good faith.
9.2 Good-faith protection
Even if a concern turns out to be unfounded, the whistleblower is protected if the report was made honestly and in good faith.
9.3 Malicious reporting
Knowingly false or malicious reports may lead to disciplinary action.
9.4 Confidentiality
Whistleblower identity is protected as described in Section 7.
You may also report directly to the official Danish external whistleblowing authority, operated by the Danish Data Protection Agency (Datatilsynet):
External Whistleblower Portal: https://whistleblower.dk (Information available in Danish.)
You may report externally before, after, or instead of reporting internally. You are not required to report internally before using the external reporting channel at Datatilsynet, and you may choose the reporting path you find most appropriate.
11.1 Compliance Committee
11.2 Compliance Officer
Committee members and compliance officer can be contacted via the whistleblower channels in Section 5 or through the main company contact details on the company website.