WHISTLEBLOWER SCHEME POLYTEKNIK A/S

1: Purpose of the Whistleblower Scheme

POLYTEKNIK A/S encourages an open corporate culture where everyone can freely report suspected irregularities or illegalities involving employees, management, the board of directors, or other stakeholders related to POLYTEKNIK A/S.

Employees are often the first to notice irregular or fraudulent behavior but may hesitate to report it. To address this, POLYTEKNIK A/S has established a whistleblower scheme that allows employees to report violations of law or other serious matters confidentially or anonymously.

The scheme aims to:

• Enable employees to speak up about illegal or objectionable conduct.
• Protect those who report through the whistleblower system.
• Detect maladministration.

The whistleblower scheme supplements, but does not replace, regular communication channels. Employees should, when possible, first contact their immediate manager, union representative, or management.

2: Scope

The scheme allows employees to make anonymous reports in cases of serious or objectionable conduct that could lead to criminal penalties, financial loss, or reputational damage to POLYTEKNIK A/S.

3: Who Can Report

All current and former employees and board members may submit a report — either anonymously or with their identity disclosed. External stakeholders (e.g., customers, suppliers, business partners) can also use the system.

4: What Can Be Reported

Reports may concern:

• Employees, directors, business partners, or suppliers.
• Systemic errors not linked to a specific person.

5: Reportable Matters

Only serious offences or suspicions thereof should be reported, such as:

• Criminal acts (theft, embezzlement, fraud, bribery, corruption, accounting manipulation, misuse of assets, etc.).
• Serious issues like discrimination, violence, assault, or harassment.
• Serious, systematic breaches of internal guidelines.

Do not use this channel for: Minor workplace issues (absence, salary, cooperation, etc.). These should go through HR or your manager.

6: How to Report

You can only submit a report electronically via our secure online whistleblower portal:

This link is also available on the POLYTEKNIK A/S intranet. For confidentiality reasons, reports cannot be sent by email or other unencrypted channels. Reports must be written in Danish.

7: Confidentiality & Anonymity

All information is handled confidentially and discreetly.

Anonymous reporters should:

• Avoid including personal details or metadata in attached files.
• Avoid submitting reports via the company’s monitored network.

For maximum anonymity, the portal supports access through the TOR browser.

8: Processing of Reports

The whistleblower system is administered by BDO Chartered Audit Company, acting as POLYTEKNIK A/S’s data processor.

BDO’s trusted employees:

• Receive and register reports.
• Forward them to the management (or to the Chairman if management is involved).
• Perform an initial review to assess admissibility.

If necessary, BDO may involve legal or external advisors to investigate the case.

9: Personal Data

Personal data is processed according to the Danish Act on the Protection of Whistleblowers (§22) and relevant data protection laws (GDPR).

10: Case Handling

Anonymous reporters receive a 16-digit key code to:

• Follow up on the report.
• Communicate anonymously with BDO.
• Receive status updates and conclusions.

Deadlines:

• Acknowledgement within 7 days.
• Case handled within 3 months.
• Reports deleted within 90 days, unless extended.
• Anonymous access remains available for up to 1 year.

11: Notification of the Reported Person

Unless there are special investigative reasons, the reported person will be informed once the case is under investigation.

12: Rights and Responsibilities

Reports made in good faith will not have negative consequences for the reporter. However, false or malicious reports may result in disciplinary or legal consequences.

13: Data Deletion

If a report falls outside the scheme or is unfounded, personal data will be deleted immediately. All reports are generally deleted after 90 days, unless extended.

14: Questions

For questions regarding the whistleblower scheme, please contact the CEO of POLYTEKNIK A/S by email or phone.