WHISTLEBLOWING POLICY

If you have reported a misconduct using the digital form, you can expect the following messages from us (this does not apply to anonymous reports):

- Confirmation of receipt: after receiving your report, you will receive a confirmation of receipt from us via e-mail within 2 working days. This e-mail contains a summary of your report.

- Decision on the report: When your report has been received and examined by our confidential adviser, you will be informed of the decision that is made on the report. You will either receive information about the next steps or the reasoning for our decision not to do anything with the report. Keep in mind we are not obliged to investigate every report, as this is not always possible, desirable or necessary.

- Findings of the investigation: When the investigation is completed you will receive a notification. This e-mail will contain the main findings of the investigation.

You may not be sure whether what you want to report is misconduct. One can speak of misconduct in so far as:

- The suspicion is based on reasonable grounds, deriving from knowledge gained by the employee from his employer or from knowledge gained by the employee from his activities in another company or organisation, and

- The public interest is at stake in the case of a violation of a legal provision, a threat to public health, a threat to the safety of individuals, a threat to environmental damage, a threat to the proper functioning of the public service or an enterprise as a result of an improper act or omission.

The reporting procedure is intended to be widely accessible. Anyone who, through his or her activities, comes into contact with misconduct in our organisation has the opportunity to report this through the reporting procedure. The procedure is thus not only open to people who currently work for Secrid, but also to former colleagues and all persons who, through their activities, have (had) dealings with our organisation. The following persons are eligible for the Secrid reporting procedure:

- Individuals who are currently working for you or have worked for you in the past, with or without an employment contract or assignment. This includes your current employees and former employees, but also freelancers, volunteers, flex workers and interns;

- Employees from other organisations who work for your organisation as contractors, subcontractors, collaboration partners or temporary workers.

Someone who has properly reported a misconduct may not be disadvantaged because of it. The reporter is also protected when reporting incidents, irregularities and breaches of integrity. A disadvantage occurs when the reporter is treated unfairly, because of the report, compared to the situation if he or she had not made the report. Note that the accused is also entitled to protection. After all, this person is innocent until proven guilty. If the reporter makes a false or untruthful report, he, she or they is/are not entitled to Protection Against Retaliation.

If you have reported misconduct and during or after the procedure you notice that you are being disadvantaged, despite the Protection Against Retaliation, you should first report this to our confidential adviser using the digital form. If this wasn’t helpful, please ask the Dutch Whistleblowers Authority to start an investigation into the way you were treated. If the Dutch Whistleblowers Authority concludes that you have indeed been wronged, you can demand compensatory measures.

Reporting misconduct anonymously offers a safe outcome for some. If you report anonymously, take into account the following disadvantages:

- The investigation of the misconduct cannot take place on an adversarial basis. We cannot contact the anonymous reporter with questions about the misconduct;

- As an anonymous reporter, you will not receive any feedback on the report;

- It is difficult to protect an anonymous reporter from retaliation.