WHISTLEBLOWER SCHEME POLYTEKNIK A/S

1: Purpose of the Whistleblower Scheme

POLYTEKNIK AS 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 AS.

Employees are often the first to notice irregular or fraudulent behavior but may hesitate to report it. To address this, POLYTEKNIK AS 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, 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 AS.

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:

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 AS’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 AS by email or phone.