Whistleblowing Policy – Gepe group

The Gepe group strives to achieve transparency and a high level of business ethics within our organisation, including all companies in our group. We are committed to the highest possible standards of transparency, honesty and accountability. It is our aim to ease and facilitate for our employees, and relevant third parties who deal with the Company’s in the Gepe group, to come forward and voice serious concerns about certain aspects of the Company’s work. This Whistleblowing policy informs you as a whistleblower about how we support you so that you can safely express your concerns, know who to contact and know how to make a whistleblowing report (“Whistleblowing report”).

The policy furthermore describes how we ensure that the support we give you is in a responsible manner and in accordance with the law, including the Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law (the “Whistleblowing Directive”). Finally, the policy also describes what rights you have and how you can exercise them.

1. Who can be a whistleblower?

You as a whistleblower can be an employee in the Gepe group or a person having self-employed status, shareholder or person belonging to the administrative, management or supervisory body of any Company in the Gepe group, as well as a volunteer and paid or unpaid trainee. You as a whistleblower can also be any person working under the supervision and direction of contractors, subcontractors and suppliers to us.

Please note that you may still be a whistleblower even though our work-based relationship has ended or if it is yet to begin.

2. Who is responsible for the Whistleblowing report?

Gepe Holding AG as the groups ultimate holding company is responsible if you make a Whistleblowing report pursuant to this policy. As such, we have a responsibility to protect you, including not disclosing your identity to anyone beyond the authorised persons that receive your Whistleblowing report (unless you explicitly consent, or we are required to disclose you pursuant to law) and making sure you are not subject to retaliation.

However, please note that you also have a responsibility in this Whistleblowing policy. We expect you to only report information and personal data that is relevant for the handling of a specific Whistleblowing report. We also ask you to not report personal work-related grievances, such as interpersonal conflicts between you and other employees or a decision relating to your employment or engagement. Personal work-related grievances should be raised with your supervisor, manager, or the HR department in your company. These issues cannot be investigated in the scope of the whistleblowing.

3. What can be can be reported in a Whistleblowing report?

The whistleblowing service can be used to alert the Gepe group about serious risks affecting individuals, our companies/organisation, the society or the environment.

The processing may only refer to data about serious improprieties concerning:

accounting, internal accounting controls, auditing matters, fight against bribery, banking- and financial crime, or

other serious improprieties concerning the company’s or the group’s vital interests or the life or health of individual persons, as for instance serious environmental crimes, major deficiencies that regard the security at the place of work and very serious forms of discrimination or harassments.

A person who blows the whistle does not need to have firm evidence for expressing a suspicion. However, deliberate reporting of false or malicious information is forbidden. Abuse of the whistleblowing service is a serious disciplinary offence.

The whistleblowing team may decline to accept a report if:

– the alleged conduct is not reportable conduct under these Whistleblowing guidelines

– the message has not been made in good faith or is malicious

– there is insufficient information to allow for further investigation

– the subject of the message has already been solved

4. How can you file a Whistleblowing report?

We enable you to file a Whistleblowing report in writing or orally, or both. Oral reporting is possible by telephone or through voice messaging system, and, upon request by you, by means of a physical meeting with such designated person as specified below.

There are different ways to raise a concern:

Alternative 1: Contact a supervisor or manager within our organisation.

Alternative 2: Contact the Gepe group whistleblowing team directly: Sven Pettersson (Group CEO), Daniela Betschart (HR Gepe Holding AG) and Sören Wilhelmsson (External Counsel) Kontakt: wb@gepe.com

Alternative 3: Anonymous or confidential messaging through the whistleblower communication channel to the whistleblowing team. The service is managed by the external party Whistleblowing Solutions AB and is available 24 hours a day. Please file a a Whistleblowing report in Whistlelink here: https://gepeholdingag.whistlelink.com

We will acknowledge the receipt of the Whistleblowing report from you within seven days of the receipt. Our whistleblowing team will maintain communication with you and, where necessary, ask for further information from you and, at the latest three months from the acknowledgment of receipt, provide feedback to you.

You can choose to file your Whistleblowing report anonymously. This does not affect your rights and protection in the EU Whistleblowing Directive. However, a complete anonymity may make it more difficult for us to investigate the issue or take the action we would like to take.

Finally, we would also like to inform you that, if you have difficulties or if internal reporting would not be appropriate, it is possible to file a Whistleblowing report externally to competent authorities and, where relevant, to institutions, bodies, offices or agencies of your country or the EU.

5. What are your rights?

We are committed to implement and maintain necessary and adequate measures in order to prohibit any form of retaliation against you by reason of filing a Whistleblowing report, including threats of retaliation and attempts of retaliation.

A person expressing genuine suspicion or misgiving according to these guidelines will not be at risk of losing their job or suffering any form of sanctions or personal disadvantages as a result. It does not matter if the whistleblower is mistaken, provided that he or she is acting in good faith.

Subject to considerations of the privacy of those against whom allegations have been made, and any other issues of confidentiality, a whistleblower will be kept informed of the outcomes of the investigation into the allegations.

In cases of alleged criminal offences, the whistleblower will be informed that his/her identity may need to be disclosed during judicial proceedings.

6. Personal data

Our goal is to always protect the personal data we process to the best of our ability. This means that we always undertake to safeguard the privacy of you and to comply with applicable personal data legislation, including but not limited to the General Data Protection Regulation (GDPR).

When you file a Whistleblowing report, we will process the personal data contained therein in order to fulfil our legal obligations according to, among other things, the Whistleblowing Directive. Please find more information about how personal data contained in a Whistleblowing report is processed here. https://www.whistlelink.com/privacy-notice/

Personal data included in a whistleblowing report and investigation documentation is deleted when the investigation is complete, with the exception of when personal data must be maintained according to other applicable laws. Permanent deletion is carried out 90 days after completion of the investigation. Investigation documentation and whistleblower messages that are archived should be anonymised under GDPR; they should not include personal data through which persons can be directly or indirectly identified.

7. Transfer of personal data outside the EEA

Data is stored within the EU. There is a general prohibition on the transfer of personal data out of the European Economic Area (EEA) unless specific mechanisms are used to protect data. The scope of this Whistleblowing guideline does not include potential transfer of personal data from the EEA to affiliates located outside the EEA

8. How do you contact us?

If you have any questions about this Whistleblowing policy and/or how to file a Whistleblowing report, please contact us via the following contact information:

Company’s contact information

Gepe Holding AG
P.O. Box 7313
CH-6302 Zug

Tel: +41 (41) 711 75 88