Whistleblowing Policy

You can use this whistleblowing channel to report serious concerns, including:

• Fraud or financial misconduct
• Corruption or bribery
• Health and safety violations
• Environmental damage
• Discrimination or harassment
• Breaches of legal or regulatory obligations

Note: This channel is not intended for personal workplace disputes that do not involve illegal or unethical behavior. These issues should be handled through HR processes.

• Confidentiality: All reports will be treated with the strictest confidentiality. Only authorized personnel will have access to the reports, and your identity will not be revealed without your consent, unless required by law
• Anonymity: If you choose to remain anonymous, you can submit your report without providing personal details. You may use a fictional email address, such as [email protected], when filling out the form. However, providing contact details may help with the investigation process.

1. Initial Report: Concerns can be reported through any of the available channels. Whistleblowers are encouraged to provide as much detail as possible, including relevant dates, individuals involved, and any supporting evidence.

2. Confidentiality and Anonymity: All reports will be treated with the strictest confidentiality. Whistleblowers may choose to remain anonymous, although providing contact details may assist with the investigation.

3. Acknowledgement: Upon receipt of a report, the company will acknowledge the complaint, where possible, within five working days.

4. Investigation: The Compliance Officer or an appointed investigator will assess the report and initiate an internal investigation if deemed necessary. The investigation will be handled impartially and in accordance with the company’s internal procedures.

5. Outcome and Feedback: Where appropriate, the whistleblower will be informed of the investigation's outcome, although specific details of the investigation may remain confidential to protect all parties involved.

The company strictly prohibits any form of retaliation against whistleblowers who raise concerns in good faith. Retaliation includes, but is not limited to:

• Dismissal or demotion.
• Harassment or victimization.
• Any form of unfair treatment or discrimination.

Any employee found retaliating against a whistleblower will be subject to disciplinary action, up to and including termination.

While the company encourages the reporting of genuine concerns, it also expects whistleblowers to act in good faith. Reports made maliciously or with the intent to harm others without any reasonable basis will be considered a violation of this policy and may lead to disciplinary action.

The Compliance Officer is responsible for overseeing the implementation of this policy and monitoring its effectiveness. This policy will be reviewed annually or when there are significant changes in legislation or company operations to ensure it remains up-to-date and fit for purpose.

This policy aligns with all relevant laws and regulations, including the EU Whistleblower Protection Directive (Directive (EU) 2019/1937), and any local Finnish regulations.