Last updated: 04.06.2026

At Submara, we build our business on trust, security, and high ethical standards. To uphold these values, we rely on transparency. We want any reprehensible conditions to come to light so that we can address them, learn from them, and implement corrective measures.

Here you will find information about our whistleblowing procedures, who can report, and how reports are followed up.

1. What constitutes reprehensible conditions?

Whistleblowing means reporting reprehensible conditions within the organization. By reprehensible conditions, we mean violations of laws, internal rules, or ethical norms. These may include:

• Conditions that endanger life and health, such as dangerous products, inadequate safety measures at work, or substance abuse 
• Incidents affecting the work environment, such as bullying, harassment, or discrimination 
• Financial matters such as embezzlement, corruption, theft, fraud, breaches of competition laws, and breaches of trust in a work context

Note: Expressions of dissatisfaction with salary, workload, or general professional disagreements are not normally considered reprehensible conditions in the context of these whistleblowing procedures.

2. Who can report?

You can use our whistleblowing channel regardless of your relationship with Submara. This includes if you work directly for Submara, are employed through a subcontractor, are a supplier, a partner, or otherwise.

• Own employees (permanent and temporary)
• Hired personnel and consultants
• Subcontractors and partners
• Customers and external parties who observe reprehensible conditions in connection with our operations.

3. How to report

You can report in the way that feels most appropriate and secure for you.

Internal channels: Employees are encouraged to report through their direct line, i.e., to their immediate manager. If this is not possible or desirable, you can report to:

• Department Manager or General Manager
• Safety Representative (SR) or Chief Safety Representative (CSR)
• HSE&Q Manager in the Group

External Whistleblowing Channel: Submara has also established a dedicated and secure whistleblowing channel. This can be used by both employees and external parties.

• Whistleblowing Form: [Link to internal/external form]
• Email: varsling@submara.no (Note: Demo email)

4. Anonymity and Protection Against Retaliation

You have the right to report anonymously. If you choose to remain anonymous, we ask that your report be as detailed as possible, as we will not be able to ask you follow-up questions.

At Submara, we have zero tolerance for retaliation. This means that no one who reports in good faith shall experience negative consequences, sanctions, or discomfort as a result of speaking up. Your identity will be treated with strict confidentiality throughout the entire process.

5. How is the report handled?

All reports are taken very seriously and are handled promptly, fairly, and confidentially.

1. Receipt: The report is registered, and you will receive a confirmation of receipt (unless you have reported anonymously).
2. Investigation: A neutral party within the company (or an external third party if needed) conducts a thorough and objective investigation of the allegations.
3. Measures and feedback: Once the investigation is complete, it will be assessed whether measures should be taken. As the whistleblower, you will receive feedback that the matter has been addressed and, to the extent confidentiality allows, the outcome of the process.