Bergstrom Climate Control Systems


Bergstrom Whistleblower Policy

Bergstrom is committed to upholding the highest ethical standards and promoting a culture of Trust and Integrity. This Whistleblower Policy aims to provide a safe and confidential reporting mechanism for individuals to report any wrongdoing including unethical or illegal behavior that they witness or are asked to participate in or simply become aware of. This policy provides employees with guidance on how to raise those concerns.

The policy also protects employees from retaliation for reporting such behavior and ensures that the Company takes appropriate action against those who violate the policy.

This policy does not form part of any contract or employment or other contract to provide services. This policy applies to all employees, job applicants, customers, suppliers, third-party vendors, and community stakeholders working with Bergstrom.


Reporting channels

Individuals can report violations through various channels, such as:

  • Reporting to local Human Resources Representative
  • Phone (United States): 1 815 873 4618



A whistleblower as defined by this policy is an individual defined within the scope of this policy who reports an activity that is considered to be illegal, dishonest, endangers the safety of others, or is contrary to Bergstrom’s Ethics Policy. The whistleblower is not responsible for investigating the activity or for determining fault or corrective measures; rather, the Ethics Committee or appropriate management officials are charged with these responsibilities. The Ethics Committee shall consist of, at least, the President & CEO and the Vice President of Human Resources.

Examples of illegal or dishonest activities are typically violations of federal, state or local laws. Whistleblowing reports may include, but are not limited to, suspicions of wrongdoing, such as:

  • Financial malpractice, misrepresentations, impropriety, or fraud, including accounting and auditing or disclosure concerns
  • Failure to comply with a legal or regulatory obligation
  • Public health and product safety
  • Risk or damage to the environment
  • Criminal activity
  • Bribery, facilitation of tax evasion or money laundering
  • Privacy and data protection breaches
  • Anti-competitive conduct
  • Harassment
  • Discrimination
  • Violations of human rights, such as modern slavery and human trafficking
  • Attempts to cover up any of these behaviors



If a whistleblower has knowledge of an activity that is considered to be illegal, dishonest, endangers the safety of others, or is contrary to Bergstrom’s Ethics Policy, this individual should attempt to report the issue to their immediate supervisor or the Human Resources Manager. Engaging with supervision or Human Resources may be a more quick and agreeable way of resolving concerns quickly and effectively. Whistleblowers must exercise sound judgment to avoid baseless allegations.

Any reports of wrongdoing should include a description of the alleged violation, the date, time, location, witnesses, and any other supporting evidence. An employee who intentionally files a false report of wrongdoing will be subject to discipline up to and including termination.

Investigation Process

All reports of wrongdoing will be promptly submitted to the Ethics Committee. The Vice President of Human Resources or their appointed designate will be responsible for investigating the matter in a timely and expeditious manner. The Vice President of Human Resources will also be responsible for coordinating any corrective or disciplinary action. The investigation shall be conducted in a fair, impartial, and confidential manner. Bergstrom shall take appropriate action against those who violate Company policy, up to and including termination.

In some cases, the company may appoint an investigator or team of investigators including staff with relevant experience of investigations or specialist knowledge of the subject matter. The investigator (or investigators) may report their findings to the Ethics Committee as well as make recommendations for change to minimize the risk of future wrongdoing.

In parallel to an internal investigation and in the event that there are elements regarding the probable commission of a crime, the company may file a corresponding complaint with the authorities and pursue legal action.


Confidentiality and Retaliation

Whistleblower protections are provided in two important areas -- confidentiality and against retaliation. When and where possible, the confidentiality of the whistleblower will be maintained. However, whistleblower identity may have to be disclosed to conduct a thorough investigation. Moreover, a whistleblower is not required to reveal their identity when filing a complaint. Bergstrom will not retaliate against a whistleblower. This includes, but is not limited to, protection from retaliation in the form of an adverse employment action such as termination, compensation decreases, or poor work assignments, or threats of physical harm. Any whistleblower who believes they are being retaliated against must contact the Vice President of Human Resources immediately. The right of a whistleblower for protection against retaliation does not include immunity for any personal wrongdoing that is alleged and investigated.


Protection and Support for Whistleblowers and Victims or Misconduct

It is understandable that whistleblowers and victims of misconduct are sometimes worried about possible repercussions. We aim to encourage openness and will support staff who raise genuine concerns under this policy, even if they turn out to be mistaken.

Whistleblowers and victims of misconduct must not suffer any detrimental treatment as a result of a concern that has been raised. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavorable treatment connected with a concern that has been raised. If you believe that you have suffered any such treatment, you should inform the HR Department immediately.

Bergstrom employees or their representatives must not threaten or retaliate against whistleblowers or victims of misconduct in any way. If an employee or representative is involved in such conduct, that individual may be subject to disciplinary action.

Disciplinary Action

Employees who violate this policy will face disciplinary action, up to and including termination. Bergstrom will also take appropriate action against contractors or third-party vendors who violate this policy.