Whistleblowerpolitikken

A 100 % anonymous and non-traceable reporting tool

Purpose
DanBred expects that our employees, as well as all representatives, subsidiaries, agents, distributors, etc. adhere to a high standard of business and personal ethics in the performance of their duties and responsibilities. As employees and representatives of DanBred P/S, we must practice honesty and integrity in fulfilling our obligations, and always comply with all existing laws and regulations.

This whistle-blower policy is intended to encourage and enable all customers, business partners and employees to draw attention to and to report possible issues, so that DanBred P/S can address and correct any inappropriate behaviour and actions. Thus, you will be able to help us identify matters that need to be addressed and improved by reporting possible breaches of DanBred P/S code of conduct or possible breaches of the laws and regulations that apply to DanBred P/S operations.

Realm of validity
This policy applies globally to the entire DanBred Group, i.e., DanBred P/S and associated companies and subsidiaries of DanBred P/S, or any entity that is controlled directly or indirectly by DanBred P/S or is under joint control or ownership with such an entity, regardless of geographical location. The initiative is administered by and on behalf of DanBred P/S as data controller.

What matters can be reported?
You are strongly encouraged to act immediately when faced with non-compliance with DanBred’s policies and procedures, such as DanBred’s code of conduct or any other applicable law or provision. Examples may include:

• Financial fraud, crime or other types of inappropriate financial practices, or practices that call into question DanBred’s accounts, financial reports, internal controls or auditing practices.

• Unregulated behaviour in relation to business practices and our code of conduct that may constitute a conflict of interest. Corruption, including payment of bribes, unethical donations, gifts to or entertainment of business partners given by employees of DanBred P/S

• Serious misconduct, including serious breaches of occupational safety, concerns about environmental pollution, serious offences against employees such as discrimination, violence or rape, or serious breaches of local policies.

• Bullying, abuse, harassment, threats and sexual undertones

It is in DanBred’s best interest that breaches of policies and rules are reported. Therefore, DanBred does not tolerate retaliation or reprisals against anyone who reports non-compliance with policies and regulations, regardless of whether their claims can be substantiated.

Collaboration and studies
Our whistle-blower hotline is administered by an audit committee, which consists of two members, HR Director and an associated external lawyer/attorney.
If you want to draw attention to a possible problem, please use the link to DanBred’s whistle-blower hotline here:

danbred (whistleblowernetwork.net)

You can write your report in your native language if you do not want to write it in Danish or English.

For the audit committee to be able to investigate the matter, you should explain and describe your experience of the possible problem in a reasonably detailed manner. The more information the audit committee receives, the easier it will be to launch an accurate investigation into the case.

You must not attempt to conduct an investigation yourself to determine whether a breach has occurred, you should instead report suspected breaches to the audit committee as described above.

With your report, you are of course guaranteed anonymity, information security and compliance with the GDPR, and our subcontractor EQS Group A/S is the guarantor of this. If for various reasons you have chosen to report in your name, we will protect your identity and treat it confidentially. Only if there is a need for a police investigation or other external investigations will we be obliged to disclose your name (if we have it) to the police to assess the information in the specific case.

Once the audit committee has received your report, the committee will investigate the matter and report it to the Chairperson of the Board, who will receive reports every six months, but will also be notified ad hoc. If needed, an independent external investigator may be used to investigate the matter.

The documentation associated with your report will be kept confidential and secure as it is stored in a cloud solution to which no external party has access.

It is important to avoid innocent people being suspected of something they have not done. Therefore, you need to consider very carefully whether what you intend to report is valid and correct before initiating a report.

Country-specific restrictions
The laws of certain countries impose specific restrictions on reporting, such as what can be reported or whether a report can be submitted anonymously.

These restrictions are built into our whistle-blower hotline:
• In Sweden, reports may not be directed at employees, but only members of management.
• In Finland, only financial matters can be reported (such as accounts, internal audits, audit cases, bribery, banking and financial crime)

Questions, information and personal data
DanBred P/S (HQ), Borupvang 5D, DK-2750 Ballerup, Denmark is data responsible for our whistle-blower policy. DanBred will process your personal data in accordance with the Data Protection Regulation (GDPR – EU) and the supplementary regulations of the Data Protection Act.

You can also contact us regarding any questions about data protection by sending an e-mail to: [email protected] , and you always have the right to lodge a complaint with the Danish Data Protection Agency, Borgergade 28, 5., 1300 Copenhagen, [email protected] the Danish Data Protection Agency .dk or your local supervisory authority.

 

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