YWCA-YMCA of Sweden has a whistleblowing system through Human&Heart for reporting and handling misconduct, irregularities, complaints, feedback, and grievances. Below, you will find information on how the whistleblowing system works.
Whistleblowing occurs when someone raises complaints about various types of misconduct within the organisation. This may involve actions that are illegal, unethical, or directly inappropriate. The issues being reported (whistleblown) should be of public interest, meaning there must be a broader concern beyond personal interests.
The whistleblowing system is based on YWCA-YMCA of Sweden’s Policy for Complaints, Feedback, and Whistleblowing, Anti-Corruption Policy, Core Values, and Code of Conduct.
The purpose of the whistleblowing system is to:
YWCA-YMCA of Sweden handles all cases submitted through the whistleblowing system. However, cases concerning the following areas will be prioritised:
Other complaints that are not deemed to be linked to corruption and/or misconduct will be handled as valuable feedback, but corrective action cannot be guaranteed.
YWCA-YMCA of Sweden cannot review complaints related to projects or programmes that are not funded or supported by/through YWCA-YMCA of Sweden.
YWCA-YMCA of Sweden’s whistleblowing system can be used by:
A complaint, concern, or other suspicion should be reported to Human&Heart through:
It is also possible to contact YWCA-YMCA of Sweden’s staff via email, SMS, or WhatsApp, primarily the programme officers. See Contact.
As an alternative to using the whistleblowing system, misconduct can also be reported directly to designated Swedish authorities without the risk of retaliation. The appropriate authority to report to depends on the nature of the misconduct. Reports should be made using the established reporting channels intended for reporting misconduct at the relevant authority.
To facilitate the subsequent investigation of the report, you are encouraged to provide as detailed a description of the misconduct as possible. You may, for example, include documents, images, and/or videos when submitting your report.
Please note that no sensitive personal data (such as information revealing ethnic origin, political opinions, religious beliefs, trade union membership, health status, or sexual life) should be included in the report unless the information is relevant to the investigation of the reported misconduct.
If possible, you are encouraged to provide your contact details to facilitate the investigation. You may be asked to provide additional information during the course of the investigation.
The whistleblower can log in using the details received when submitting a complaint through the whistleblowing system. You may remain anonymous to the case officer. If you have chosen to provide contact details, the case officer may contact you to ask any necessary questions. Your contact details will not be disclosed by Human&Heart without your explicit consent.
During the investigation or after its conclusion, it may be necessary to disclose information that could identify you. If this is required, your explicit consent will be obtained before any such disclosure occurs. Information may also be shared with relevant authorities. You will be informed if such disclosure is to take place, provided that doing so does not hinder or complicate the purpose of the disclosure.
Unless you have submitted an anonymous report, you will receive information on follow-up measures taken in response to your report, as well as the reasons for these actions, within a reasonable time—no later than three months after receiving confirmation that your report has been received. This is subject to the condition that providing such information does not compromise the internal investigation or affect the rights of any involved parties. Where appropriate and possible, you will be kept informed of the progress of the investigation and any follow-up measures taken as a result of your report.
Regardless of the type of investigation conducted, the individual reporting misconduct is protected by confidentiality and safeguarded against retaliation or obstructive measures.
The whistleblower has the legal right to remain anonymous both in relation to the recipient of the complaint (e.g., Human&Heart) and to YWCA-YMCA of Sweden. However, it is encouraged that the complainant feels able to be open about their identity to facilitate the best possible investigation of the reported incident.
All processing of personal data within the framework of YWCA-YMCA of Sweden’s whistleblowing system is carried out in accordance with applicable legislation. Processed personal data is normally deleted within two years after an investigation into a reported misconduct has been concluded.
When assessing and investigating reports made via the whistleblowing service, our partner Human&Heart processes personal data as the data controller, following their policy on privacy.
YWCA-YMCA of Sweden has chosen to have all complaints received and investigated by the external organisation Human&Heart HR AB and their whistleblowing system Trust&Heart to ensure legal certainty. The whistleblowing system is used to report all types of misconduct or irregularities of public interest.
YWCA-YMCA of Sweden has an investigation committee consisting of the organisation’s programme officer, association support function, and the Secretary General. The investigation committee is responsible for handling complaints, with the programme officer being primarily responsible for the process.
A description of YWCA-YMCA of Sweden’s complaint handling process is found below.
A complaint is received and registered in the whistleblowing system by Human&Heart. The complainant is provided with an ID and password to follow the status of the case through the digital whistleblowing platform.
If a complaint is not submitted via the whistleblowing system, it may be received by YWCA-YMCA of Sweden through other channels – such as email, WhatsApp, or phone. In such cases, step 2 does not apply.
The desk officer at Human&Heart assesses the complaint. The handler may decide not to proceed with an investigation in cases where:
The desk officer at Human&Heart may request contact with the complainant. Communication can take place without disclosing the complainant’s identity.
Human&Heart contacts YWCA-YMCA of Sweden’s Investigation Committee to present the complaint for review and determine whether further investigation is required. Human&Heart submits a recommendation for continued handling and decides which member of the committee is most appropriate to receive the case.
If the complaint is not submitted via the whistleblowing system but instead received by YWCA-YMCA of Sweden directly (e.g. email, WhatsApp, or phone), the committee’s primary responsible member is informed. If that individual is affected by the complaint, the Secretary General is informed instead.
If a member of the Investigation Committee is named in the complaint, that individual is excluded from the process. If the Secretary General is the subject of the complaint, the Board will be involved in the committee. A staff member responsible for the project or area concerned may be called in if needed. Responsibility for the case is assigned to the manager of the relevant project/area unless that person is implicated, in which case the Secretary General appoints another staff member or assumes responsibility personally.
The committee determines whether YWCA-YMCA of Sweden can and should handle the matter and whether it should be managed internally or referred to another actor.
YWCA-YMCA of Sweden may be obligated to report suspected corruption and/or misconduct to other actors involved in the project or programme in question, such as donors or partner organisations, depending on the context and content of the complaint. If the matter relates to activities funded by other donors, those donors will also be informed.
If there are grounds to believe that misconduct or other serious issues have occurred, an investigation is initiated. The form of investigation depends on prior decisions. It may be conducted internally (by staff at KFUM Sweden or partner organisations) or externally (e.g. donors or external consultants).
The Investigation Committee conducts the inquiry in consultation with Human&Heart and, if relevant, other actors (see point 4).
To ensure appropriate action, additional information may be required from the complainant. The time needed for this process may vary depending on the case and the stakeholders involved.
Once an investigation has been concluded, the responsible person (see point 3) shall recommend appropriate measures. Together with the Investigation Committee, the Secretary General and/or other relevant actors, the responsible person shall decide on suitable actions, ensure that corrective measures are implemented, and document the status of their implementation.
YWCA-YMCA of Sweden will produce a report summarising the case, the handling process, assessments, actions and recommendations.
The whistleblower will receive feedback from Human&Heart in the external whistleblowing system regarding their assessment of the case.
YWCA-YMCA of Sweden will provide follow-up information on the case status within 14 and again 30 working days after the organisation has received the case. The whistleblower will also receive the outcome of the investigation and subsequent decisions in the form of the final report.
YWCA-YMCA of Sweden cannot guarantee a specific timeframe for the conclusion of investigations. During July, response times are longer due to staff leave. In cases of system or e-mail malfunction, delays or loss of information may occur.
If the whistleblower has requested anonymity, YWCA-YMCA of Sweden cannot provide them with the final report.
Whistleblowers whose cases do not concern corruption and/or misconduct will receive an explanation of why no further investigation will be conducted, along with feedback on how YWCA-YMCA of Sweden will address the matter going forward.
The case may be escalated to the donor funding the project/programme concerned, or to the relevant authority.