WHISTLEBLOWING CHANNEL —

Report misconduct and ensure ethical standards

We strive to be an honest and reliable partner for customers, Cimcorpers, suppliers and other stakeholders around the world. Recognizing and implementing our code of conduct ensures a responsible and professional work culture.

To ensure high standards of ethics at Cimcorp we offer a whistleblowing channel, which is open for anyone to inform us of any misconduct or abuse. The whistleblowing channel is provided by an external company, WhistleB, to ensure anonymity. You can use the same whistleblowing channel and give your name, if you prefer.

The WhistleB reporting channel enables anyone to report suspicions of serious misconduct in confidence. The channel is encrypted and password-protected.

It is important for Cimcorp to foster high ethical standards in all our business practices wherever we operate. We consider whistleblowing to be an early warning system to reduce risk and an important tool for fostering good business ethics and maintaining trust. Therefore, we encourage you to voice your concerns and report suspicions of misconduct.

All reports will be processed in confidence.

Reporting misconduct

The whistleblowing channel can be used to report any suspected misconduct or abuse related to Cimcorp’s activities.

Instructions for reporting

As a global group, we are committed to conducting our business in a responsible and sustainable manner, no matter where we are in the world. In order to promote the long-term interests of Cimcorp and our stakeholders, we strive to maintain the highest legal and ethical standards in all our business practices.

Every Cimcorper is expected to act responsibly and with integrity and honesty. We will speak out against any unethical business practices or misconduct in and around our business, and expect this from our stakeholders as well.

When everyone plays their part and acts in good conscience, we can achieve better results.

When to report

Use our anonymous and reliable whistleblowing channel WhistleB.

The whistleblowing channel is administered by WhistleB, which – as a neutral service provider – ensures that the reports are processed anonymously. Your personal information and identity can be hidden and neither WhistleB nor Cimcorp will be able to identify you. Through the reporting service, an anonymous whistleblower and those processing the report can communicate without revealing their identities.

What follows a report?

All reports are taken seriously and processed confidentially following our procedure. Only the named whistleblowing management team processing reports can access the data through the whistleblowing channel.

Each report is subject to the duty of non-disclosure, which guarantees confidential processing of reports. While a report is being processed, the whistleblowing management team may turn to other people for information and expertise. This is also done confidentially. In addition, a summary of the reports will be shared with Cimcorp’s top management.

Once a report has been received, the whistleblowing management team makes a decision to either accept or reject it. If the report is accepted, the appropriate steps to investigate it will be taken.

The report may be rejected if

• the incident should be handled by another party, e.g. internal HR matters
• the report is false or malicious
• sufficient information for investigating the matter further is not available
• the issue has already been resolved

Any intrusive information of a personal nature concerning areas such as health or political, sexual or religious ideas will not be investigated.

How does the investigation happen?

All accepted reports are investigated thoroughly. Every report and piece of information regarding the issue is highly confidential and handled with integrity. Anyone involved in the issue will not participate in the investigation.

If necessary, officials may ask for further information using the anonymous WhistleB service. We will not try to figure out the identity of the person who submitted the report.

No one who reports in good faith will incur negative consequences

Where the report concerns a criminal offence, the whistleblower will be told that revealing their identity may be necessary in connection with a pre-trial investigation carried out by the authorities and a court hearing.

No one who reports their suspicions in good faith and participates in investigating potential breaches of our Code of Conduct will incur negative consequences as a result. Abuse of the whistleblowing channel, or deliberately reporting false information, is a serious violation that may have further consequences.

All personal information contained in reports will be removed once it is no longer needed for investigation and implementation purposes and, in general, within one month (30 days) after the conclusion of the investigation. The investigation documents will be anonymised and name and address data, as well as any other information that may allow the identification of the person in question either directly or through other data, will be removed.

These instructions are based on guidelines issued by a working party on the protection of individuals with regard to the processing of personal data referred to in Article 29 of Directive 95/46/EC (Data Protection Directive) and on the EU’s General Data Protection Regulation of May 2018. A blanket ban on disclosures of personal data to non-EEA parties is in force unless specific measures are taken to protect the data.

Report any suspected abuses related to Cimcorp’s activities

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