PURPOSE
Hans Aa is committed to maintaining high integrity and ethical conduct.

Our Whistleblower Policy provides a confidential and secure way to report legal violations or serious misconduct within our company. It ensures that concerns are addressed appropriately while protecting whistleblowers from retaliation.

The Whistleblower Scheme covers reports related to serious violations, including but not limited to financial misconduct, bribery, fraud, public health risks, environmental violations, and data protection breaches under EU law.

REPORTING CHANNEL
Employees and external stakeholders can submit a whistleblower report through a designated reporting form through our website. Reports can be made anonymously.

HANDLING PROCEDURE

• Reports are securely stored and only accessible to the appointed Whistleblower Committee.
• The Whistleblower Committee consists of one representative from each of our locations: China, Poland, and Denmark, appointed by the Board of Directors.
• The Whistleblower Committee is responsible for communicating with the whistleblower if contact information is provided.
• All reports are assessed and documented. If a violation is confirmed, appropriate corrective measures, including disciplinary or legal actions, will be taken.
• The Whistleblower Committee will acknowledge receipt of the report within 7 days.
  A follow-up investigation will be conducted, and the whistleblower (if not anonymous) will be informed of the outcome within three months.
• Reports related to interpersonal conflicts, minor HR issues, or violations of internal guidelines not categorized as serious offenses will not be processed under this scheme.
  Such matters should be raised through normal internal communication channels.

CONFIDENTIALITY & PROTECTION

• Whistleblowers are protected against any form of retaliation.
• Identities remain confidential unless disclosure is required by law or necessary to address a serious legal violation.
• The whistleblower's identity will not be disclosed to the reported persons unless required by law. However, the nature of the report may make identification possible.
• All personal data is processed in compliance with GDPR.

ESCALATION PROCEDURE

• If the whistleblower believes their report has not been handled appropriately, they can escalate the case to the relevant authorities per national and EU Whistleblower Protection Laws.