Speak up Policy

I. Introduction

A. Purpose

The purpose of the Speak Up Policy (“the Policy”) is to explain what employees of ENVEA (“ENVEA” or the “Group”) must do if they encounter or suspect any misconduct. It should be read in conjunction with the Code of Conduct and other Group policies and procedures. This Policy applies in addition to any business-unit specific policies that are in place.

The Group is committed to conducting business with honesty, transparency, integrity and to comply with internal and external regulations and laws. The Group encourages everyone to speak up, in case of observing any violations or suspicion of misconduct in violation of applicable laws or regulations, the Code of Conduct, or our policies and procedures. All reports made in good faith will be taken seriously, handled confidentially and without retaliation.

B. Scope

The Policy applies to everyone working for the Group regardless of contract type (including permanent, temporary, agency workers, interns, external and hired in staff) location, role or level of seniority (“Employees”). The Policy is available to all related parties (i.e., customers, suppliers, agents, distributors, representatives and shareholders) who wish to raise a concern involving a person who carries out work for the Group.

II. When to speak up

The Policy can be used to raise concerns about misconduct and suspected misconduct. Employees must take responsibility for reporting misconduct or suspected misconduct, regardless of seniority in the Group.

Employees must speak up if:

1. You believe that someone acting on behalf of ENVEA is doing, has done or might be doing something that violates applicable laws and regulations, the Code of Ethics, and/or ENVEA policies and procedures;

2. You are unsure about the proper course of action and are in need of advice;

3. You believe that you may have been involved in misconduct; or

4. You believe that someone who followed the Policy in good faith has been subject to retaliation.

The Policy is not intended to be used to settle individual complaints or to make false accusations.

III. How to speak up

Employees must report misconduct or suspicion of misconduct. By doing so, you give the Group the opportunity to look into the matter and to define appropriate actions. This is the best way to create a positive, open working environment throughout the organization. Except as required by applicable law, or if reporting serious and imminent danger or irreversible damage, in order to be protected, employees are bound to speak up internally first, before reporting to any external authorities.

A. Speak up Internally

If you encounter any misconduct or suspect any misconduct, please feel free to speak up through one of the channels below:

  • Your supervisor usually is the right person to bring up a compliance or integrity issue.
  • Your local Human Resource representative.
  • You may also get help or advice from the Chief Executive Officer.

If you are unable or feel uncomfortable raising the matter through one of the above channels, you can also raise your concern to the Designated Officer1.

B. What kind of information do I need to provide?

You should speak up with the facts you have. Employees should not conduct their own investigations. Whether you share your concern in person, in writing or by email, please provide as much detailed information as possible. Please include:

  • The background, history and reason for the concern
  • Data, places, and if possible people’s names and other relevant information
  • Examples of the behavior in question
  • Any documents that may be relevant to the situation

It is also good to mention whether you have already discussed the situation with someone, and if so, with whom and when.

C. Speak Up Externally

Employees are bound to speak up internally first. The Group accepts that there are some situations in which you are not able to speak up internally. In that case you should speak up externally, in line with all applicable laws and regulations. Examples of these situations include:

  • When you are in acute danger;
  • When it is your legal duty;
  • When you are in a reasonable fear of serious retaliation as a result of internal reporting;
  • When you have a reasonable fear that evidence will be destroyed; and
  • When an earlier, internal report has not been handled appropriately in a reasonable timeframe.

1 A complete list of Designated Officers and corresponding responsibilities is included in Appendix A of the ENVEA Code of Conduct.

IV. What happens after you speak up

A. Reporting and Process

Every report of a potential compliance issue will be taken seriously:

  • If you speak up, you will receive a confirmation of the receipt of your issue as soon as possible and at the latest within seven working days;
  • Your report will undergo an initial review in order to determine whether further investigation is required;
  • If further investigation is considered appropriate, you may be approached to provide additional information. All investigations will be conducted objectively, in full confidentiality and in accordance with all applicable laws and policies. At this stage, external experts such as lawyers or accountants can be engaged to assist with an investigation;
  • As the reporting party, you will be informed of the processing of your report within 3 months or 6 months if justified, and whether misconduct has been confirmed but you will not be provided with further details; and
  • The party responsible for conducting the investigation will report the outcome to the Executive Board or Board of Directors. This will be done as soon as possible and within two months of the initial report being received.

B. Involved in an investigation

The Designated Officer is the party responsible for conducting any investigations or coordinating with the Executive Board or Board of Directors to identify the appropriate internal or external party to lead an investigation. If you become involved in an investigation, you need to cooperate and answer all questions completely and honestly. All parties involved, including the accused, are entitled to confidentiality in order to avoid unnecessary damage to their reputation. Therefore, if you participate in or learn about an investigation, you must keep the matter confidential.

V. Protection and confidentiality

All reporting of misconduct or suspected misconduct is confidential and will be carefully studied.

This means your report will only be shared with a limited number of people, all of whom will be under an obligation to keep the report confidential. It is not possible to report through an anonymous helpline; however if you do not feel comfortable to discuss the issue in person as a first step, you can send an email to your supervisor and/or Human Resources department for your business unit.

If you are unable or feel uncomfortable raising the matter to a supervisor and/or within your department, you can also raise your concern to the Designated Officer.

The Group guarantees that the identity of any person reported and all reports will be treated confidentially.

The Group is committed to protect the privacy of our Employees.

We will do everything reasonable to safeguard personal data from unauthorized access and processing. You could send an email to the Human Resources department for your business unit in order to gain access to your personal data and, as the case may be, to rectify, complete, update, block or delete this data.

A. Non-retaliation

Employees who, in good faith, seek advice, raise concerns relating to (real or suspected) misconduct in accordance with the Policy are doing the right thing. The Group will not allow retaliation against that Employee. Any retaliation will, itself, be misconduct and should be reported in accordance with the Policy.

VI. Compliance procedures and training

All Group Personnel shall receive and review a copy of this Policy. ENVEA will provide periodic training programs or modules to educate Group Personnel about the requirements and obligations of this Policy. Group Personnel must participate in this training when required and the Designated Officer will retain attendance and/or completion records establishing compliance with this requirement.

VII. More information

If you have any questions regarding this Speak Up procedure or need further assistance, please contact the Group Human Resource Manager. For more information about this policy, please contact the Designated Officer.