1. Purpose & Objective

The overall purpose of AGRAMKOW’s whistleblower Policy is to increase possibilities for employees and other people – see below – to raise their voice about criticizable conditions in the workplace, without fearing for negative consequences. The purpose of the whistleblower policy is to ensure openness and transparency about any non-compliance or (criminal) offence and serious irregularities.

The whistleblower policy is a supplement to the direct and day-to-day communication about i.e. discrepancies and unsatisfactory conditions in the company. Furthermore, the policy is a supplement to existing channels, i.e. employees can contact their manager, People & Culture, the union representative, or the Safety Committee, if they witness discrepancies, non-compliance or offences. 

AGRAMKOW urge to the use the direct and day-to-day communication as described above, in those cases, where potential irregularities can be handled effectively internally and where the whistleblower assesses that there is no further risk of reprisals. The whistleblower channel should only be used in cases, where the Whistleblower does not feel safe to come forward through the line organization. 

The policy describes AGRAMKOW’s guideline for reporting, assessment, handling and follow-up on reported incidents under the internal Whistleblower Policy. 

2. Scope 
This Policy applies to all stakeholders of AGRAMKOW Group Aps. 

3. What is Compliance
Compliance means that everyone in the company adheres to the applicable rules, including legal requirements and internal company policies, such as the Code of Conduct. Compliance enables all employees to behave in an ethically correct manner.

3.1 Why is compliance important?
At AGRAMKOW, it is expected that all employees will comply with legal and internal company requirements. Ultimately, non-compliance negatively impacts not only the individual committing the act but also the rest of the company.

4. Policy Statement
Whistleblowers can use AGRAMKOW Fluid Systems A/S’s whistleblower scheme to report any information, including knowledge or reasonable suspicion of actual or potential violations that have occurred or are highly likely to occur at AGRAMKOW Fluid Systems A/S, as well as attempts to conceal such violations. This includes, but is not limited to:

• Corruption
• Bribery
• Theft
• Embezzlement
• Fraud
• Sexual harassment
• Severe harassment, e.g., based on race, gender, color, language, wealth, national or social origin, political or religious affiliation.

A violation or other matter is generally serious if it is in the public interest to disclose it. Whistleblowers can report matters that have occurred or will occur at AGRAMKOW Fluid Systems A/S. It is required that the whistleblower acts in good faith regarding the accuracy of the information.

4.1 What cannot be reported:
Minor violations are not covered, nor are violations of accessory provisions (e.g., failure to comply with documentation requirements). 

Information about other matters, such as violations of internal guidelines on sick leave, smoking, alcohol, dress code, and private use of office supplies, as well as information about the whistleblower's own employment relationship, including disagreements with colleagues and cooperation difficulties, are generally not serious violations – in these cases, we recommend contacting your manager or People & Culture. Such information should not be reported to AGRAMKOW’s whistleblower scheme unless it involves sexual harassment or other forms of severe harassment. Appendix 1 provides more examples of serious violations and other serious matters covered by the whistleblower scheme. 

5. How violations can be reported
Whistleblowers can report matters by written communication via email to: whistleblower@agramkow.com or fill in the form below. Currently, anonymous reports cannot be made. This decision is based on our company’s commitment to thoroughly handling each case. At the same time, there may be a need for further clarification of the individual potential violation. Reporting will be confidential with the HR Manager or CFO. 
In cases where the report involves the CFO or HR Manager, the CEO must be involved.  

5.1 Handling of reports:
After a report, AGRAMKOW’s whistleblower unit will confirm receipt immediately. This will be done in the form of an auto-generated receipt from the company's email system. 

AGRAMKOW’s whistleblower unit will then carefully follow up on the report. The content and character of the report are crucial for determining how follow-up actions should be conducted. 

The whistleblower unit will first assess whether the report falls within the scope of the whistleblower scheme. If the report is outside the scope of the scheme or is clearly unfounded, it will be rejected, and the whistleblower will be informed accordingly. If the report is within the scope of the law, it will be processed. 

This includes, among other things, that AGRAMKOW’s whistleblower unit, depending on the content and character of the report, will obtain further information internally within the organization or group. Under certain circumstances, it may also involve further dialogue with the whistleblower.

5.2 Examples of follow-up:

• Initiation of an internal investigation within the company.
• Notification of the company's top management or board.
• Reporting to the police or relevant supervisory authority.
• Case closure due to lack of or insufficient evidence. 

The whistleblower unit will provide feedback to the whistleblower within three months from the confirmation of receipt of the report. This means that the whistleblower unit will inform the whistleblower about the actions that have been initiated or are planned to be initiated, and the reasons for choosing this follow-up.

If it is not possible to provide feedback within the deadline, AGRAMKOW’s whistleblower unit will inform the whistleblower of this and whether further feedback can be expected. This may be due to an internal investigation that cannot be completed within the deadline. Feedback must comply with applicable laws, including data protection laws. This means, among other things, that there must be a basis for disclosing sensitive information. It depends on a concrete assessment of what information can be provided in the follow-up to the whistleblower.

6. Roles & Responsibilities
The AGRAMKOW Whistleblower channel is administrated by

• HR Manager, Marianne Plougstrup and
• CFO, Mads Horst Johannsen

If the report concerns the HR Manager or CFO then we advise a direct communication to our CEO, Søren Eriksen Nielsen.

6.1 Persons who can submit information to the whistleblower scheme:
The following groups can use AGRAMKOW Fluid Systems A/S’s whistleblower scheme:

• Employees of AGRAMKOW
• Management and board members
• Suppliers, customers, and other partners

7. Protection of Whistleblowers
A whistleblower must not experience threats, or retaliation attempts due to reporting or disclosing violations through the whistleblower scheme. It is also not permitted to prevent or attempt to prevent the whistleblower from reporting violations. Retaliation is any form of unfavorable treatment or unfavorable consequence in response to an internal or external report that causes or may cause harm to the whistleblower. The whistleblower cannot be held responsible for reporting confidential information if they have reasonable grounds to believe (in good faith) that the information in a report is necessary to disclose a serious violation or serious matter. Attempts by AGRAMKOW Fluid Systems A/S’s employees or management to prevent a whistleblower from making a report or to retaliate against a whistleblower who has reported in good faith will result in employment-related consequences.

8. APPENDIX 1
Examples of serious violations and other serious matters covered by the whistleblower scheme.

• Illegal activities (e.g., fraud, bribery, theft)
• Violations of AGRAMKOW's policies or ethical guidelines
• Dangerous or harmful behavior that could put employees or customers at risk.
• Abuse of power or position within AGRAMKOW
• Other behavior that contravenes general legislation or the company's values