Aquagain's Whistleblower Scheme

We are committed to transparency, integrity, and an ethical business environment. To ensure that these values are an integral part of our corporate culture, we have implemented a whistleblower scheme for our employees. The scheme also applies to employees in temporary positions and substitutes.

Why a Whistleblower Scheme?
In our efforts to maintain high standards of business ethics and accountability, we recognize that employees should have the opportunity to report potential irregularities or concerns about our practices. The whistleblower scheme is a tool that empowers our employees to bring any issues they may encounter to our attention without fear of retaliation.

The whistleblower scheme should be seen as a supplement to your opportunity as an employee to approach management if you identify errors or unsatisfactory conditions that you wish to highlight.

How does it work?
Our whistleblower scheme provides employees with an anonymous and secure platform to report concerns or actual knowledge of violations, including but not limited to:

• Public tenders/procurement
• Money laundering and financing of terrorism
• Protection of privacy and security of network and information systems
• Consumer protection
• Economic crimes such as embezzlement, theft, bribery, fraud, and document forgery
• Hacking, wiretapping, recording of conversations, among others
• Violations of accounting laws, tax legislation, etc.
• Breach of confidentiality
• Disregard of legal duty to act
• Violation of rules on the use of force
• Serious and repeated violations of administrative and public access laws
• Serious and repeated violations of administrative law principles, including the principle of investigation, requirement of objectivity, the principle against abuse of power, and proportionality
• Deliberate misinformation of citizens and collaborators
• Physical and psychological violence and sexual offenses or severe harassment based on race, gender, language, financial status, national or social origin, political or religious affiliation
• Neglect of professional standards that may pose a risk to the safety and health of individuals
• Neglect of duty
• Severe or repeated violations of the company's internal guidelines on, for example, business trips, gifts, and accounting
• Serious errors and serious irregularities associated with IT operations or IT system management.

The whistleblower law does not apply to information of trivial nature or information about, for example, violations of internal guidelines on sick leave, smoking, alcohol, dress code, private use of office supplies, or violations of accessory provisions such as failure to comply with documentation requirements.

Protection of Whistleblowers
As a whistleblower, you have the right to remain anonymous throughout the process. The whistleblower scheme is designed and managed in a way that ensures confidentiality about the identity of the whistleblower and the affected persons mentioned in a report. The IT system used to handle the whistleblower scheme is subject to stringent security requirements, including anonymity and confidentiality.

Aquagain collaborates with Whistleblower Partners on an external whistleblower portal. Employees can access the portal by scanning the QR code available on various bulletin boards in the building.