Introduction

At Nedinsco, we place great importance on integrity and transparency. We encourage our employees and stakeholders to report suspected misconduct without fear of retaliation. This whistleblower policy outlines the procedure for reporting such suspicions and the protection afforded to whistleblowers.

Purpose & scope

This policy aims to:

• Provide a safe and confidential means for reporting suspected misconduct.
• Protect whistleblowers from retaliation resulting from their reports.
• Foster a culture of openness and accountability within Nedinsco.

This policy applies to all employees, including temporary staff, interns, suppliers, and other individuals who have or have had a working relationship with Nedinsco.

Definitions

Misconduct: A suspected irregularity or violation of European Union or national laws that harms public interest. Examples include fraud, corruption, breaches of environmental laws, or serious safety risks.

Whistleblower: An individual who reports a suspected misconduct and has or has had a working relationship with Nedinsco.Nedinsco B.V. processes your personal data for the following purposes:

Internal reporting procedure

Reports of suspected misconduct can be made to:

• Confidential Advisors: Ans Hendrix (ans.hendrix@nedinsco.nl) and Leon Hanssen (leon.hanssen@nedinsco.nl)

Upon receiving a report, an acknowledgment will be sent within seven days. The investigation into the report will be conducted within a reasonable timeframe, during which the whistleblower will be kept informed of the progress and outcomes.

External reporting procedure

If the internal procedure does not resolve the issue adequately, the whistleblower may contact external bodies such as:

House for Whistleblowers: https://www.huisvoorklokkenluiders.nl/

Relevant Supervisory Authorities: Depending on the nature of the misconduct.

Protection of the whistleblower

Nedinsco guarantees that:

• Any retaliation will be promptly addressed and rectified.
• The identity of the whistleblower will be treated confidentially.
• The whistleblower will be protected against any form of retaliation resulting from the report.

Confidentiality & anonymity

Reports can be made anonymously if desired. All information will be handled with strict confidentiality and shared only with individuals directly involved in the investigation.

Documentation & record-keeping

All reports and subsequent actions will be carefully documented and stored in accordance with applicable privacy laws.

Communication & training

Nedinsco ensures:

• Accessible information about reporting procedures and protective measures.
• Regular training and awareness programs about this whistleblower policy for all employees.

Evaluation & revision

This policy will be evaluated annually and adjusted as necessary to comply with new laws, regulations, or internal developments.

Final provision

For questions or clarifications, employees can contact the confidential advisor or the HR and/or Compliance departments. By establishing and implementing this policy, Nedinsco promotes a culture of openness and integrity within the organization.