Skip to main content

ALBA TANKERS – WHISTLEBLOWER POLICY

 

1. ABOUT THIS POLICY

1.1 Commitment to integrity 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. 1.2 Purpose of this Policy 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:

  • The Open Reporting Module, which allows all employees to report health, environmental, and safety non-conformances, hazards, near misses, improvement suggestions, or other operational issues—either anonymously or non-anonymously at the reporter’s request.
  • The complaint procedures established in Alba Tankers’ internal policies and procedures.
  • Normal management or HR channels, where relevant.

This policy is designed to:

  1. a) Encourage and enable individuals to report suspected wrongdoing or misconduct as early as possible, with confidence that concerns will be taken seriously, investigated appropriately, and treated confidentially. b) Provide clear guidance on how to raise concerns under safe reporting conditions. c) Reassure individuals that they may raise genuine concerns without fear of reprisals or negative consequences, even if the concern later proves unfounded.

 

2. WHO DOES THIS POLICY APPLY TO?

This policy applies to all individuals who work with or for Alba Tankers, including:

  • Employees
  • Officers
  • Members of management
  • Crew (employed also through our crewing partners)
  • Consultants, contractors, and self-employed persons
  • Suppliers and subcontractors
  • Interns, trainees, and volunteers
  • Persons working under the supervision of Alba Tankers’ contracting parties
  • Former employees or others who have obtained information through a previous work-related relationship
  • Applicants and persons who have obtained information during recruitment or other pre-contractual activities

These groups are protected under the Danish Whistleblower Act.

3. RESPONSIBILITY FOR THIS POLICY

3.1 Governance – Compliance Committee Alba Tankers has established a Compliance Committee, consisting of Jørgen Olesen (Group CEO), Daniel Staszczyk (HSEQ Manager/DPA) and Anders Lindqvist (Board Member) who have overall responsibility for the company’s whistleblowing framework. The Committee oversees the effective functioning of the whistleblowing framework and review actions taken in response to reported concerns. 3.2 Operational responsibility Day-to-day responsibility is assigned to the Compliance Officer, who must ensure:

  • Proper handling of reported concerns
  • Confidentiality and impartiality
  • Training of managers and relevant staff
  • Review recommendations to the Compliance Committee

  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. WHAT IS WHISTLEBLOWING?

Whistleblowing means reporting information related to serious misconduct, wrongdoing, or significant risks solely. Examples include, but are not limited to:

  1. a) Illegal or criminal activity b) Theft, fraud, forgery, embezzlement c) Breach of legal or regulatory obligations d) Health and safety risks or serious maritime safety concerns e) Environmental damage or pollution risks f) Bribery, corruption, or collusion g) Money laundering or terrorist financing h) Tax evasion i) Material breaches of internal policies or the Code of Conduct j) Conduct harmful to Alba Tankers’ reputation or operations k) Severe harassment, discrimination, violence, or similar behavior l) Breaches of privacy, GDPR, or information security m) Concealment of any of the above

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 if you can address your concerns with your nearest superior, our People & Culture department or our company CEO. 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. RAISING A CONCERN

5.1 Initial reporting In many cases, concerns can be raised directly with your manager or with People & Culture, 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:

Postal mail: Alba Tankers ApS Att: Compliance Officer Tagholm 15 DK-9400 Nørresundby Denmark All reports will be handled confidentially and promptly.

6. WHEN REPORTING – INFORMATION REQUIRED

To support an effective investigation, please provide as much detail as possible, including:

  1. a) Description of the matter b) Companies or persons involved c) Dates, times, and locations d) How you learned of the matter e) Whether anyone else is aware f) Any relevant documents or evidence g) Duration of the issue h) Any attempts to conceal the matter

Providing detailed information enhances the ability to investigate thoroughly.

7. ANONYMITY

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:

  • With your explicit consent,
  • Where required by law (e.g., legal proceedings), or
  • When necessary to prevent serious crime or protect life or safety.

Confidentiality also applies to any individuals mentioned in the report (“affected persons”), in accordance with the Danish Whistleblower Act.

8. INVESTIGATION AND OUTCOME

  • You will receive acknowledgment of your report within 7 days, unless no contact information is provided.
  • The Compliance Officers will conduct an initial assessment to determine the scope and next steps.
  • Additional information may be requested if needed.
  • You will receive feedback on the progress or outcome within 3 months of acknowledgment.
  • Confidentiality will be maintained to the fullest extent legally possible.

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. PROTECTION AND SUPPORT FOR WHISTLEBLOWERS

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.

10. EXTERNAL REPORTING

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. CONTACT DETAILS 11.1 Compliance Committee

  • Jørgen Olesen, Chief Executive Officer (Group CEO)
  • Daniel Staszczyk, Designated Person Ashore (DPA)/QA Manager
  • Anders Lindqvist, Board Member

11.2 Compliance Officer

  • Håkan Kalmerlind, Chief Operational 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.