The purpose of the Whistleblower Policy is to explain how the whistleblower scheme works at Akurat. The policy also aims to ensure that potential reviews are not lost due to uncertainty about the scheme.

Akurat’s Whistleblower Scheme

Akurat has established a whistleblower scheme that complies with EU Directive 2019/1937.

Akurat’s whistleblower scheme is handled by WhistleSystem ApSwhich ensures a completely anonymous and secure reporting process for the whistleblower. The whistleblower scheme must be used if employees or other stakeholders experience serious misconduct or offenses that occur in, or in connection with, Akurat. The matters that can be reported are described further in the whistleblower policy under “What can be reported?”.

Akurat encourages you to contact your immediate manager when you experience misconduct or violations of the law and report the incident. However, this is not always the most optimal approach and can cause reviews to be lost. Therefore, Akurat has established a whistleblower scheme, which in the event that you do not want/can go to your immediate manager or wish to remain anonymous, makes it possible for you to still report the misconduct.

Notifications can be made by anyone who has access to the scheme. At Akurat, this includes internal stakeholders who have been made aware of misconduct.

The whistleblower’s report can concern people, situations and incidents. The people who can be reported are basically all stakeholders, as long as the report is relevant according to the criteria under “What can be reported?” below and in connection with Akurat.

What can be reported?

The whistleblower scheme can only be used if the report concerns serious misconduct or violations. This means that things like collaboration difficulties, dissatisfaction with facilities, or dissatisfaction with terms and conditions cannot be reported through the whistleblower scheme. In such cases, refer to your immediate manager.

Examples of areas that can be reported through the whistleblower scheme include, but are not limited to, the following.

• Sexism
• Sexual harassment
• Physical violence
• Discrimination
• Financial crime
• Occupational safety
• Consumer protection
• Product safety
• Breach of procurement law
• Breaches of personal data legislation
• Breaches of environmental legislation
• Money laundering

However, it is Akurat’s policy that we would rather have one review too many than one too few to ensure we receive all relevant reviews. This means that if you are unsure whether your review falls under the above, you are encouraged to send the review.

How to report?

The whistleblower can access and report through WhistleSystem as follows:

1. Go directly to Akurat’s Whistleblower System

2. Fill out the form with the necessary information for the administrators to handle the notification. Reporting in the system is anonymous. WhistleSystem is the only channel where reviews can be made anonymously.

The login can be used by all relevant stakeholders that Akurat has requested to have access to the whistleblower scheme.

After the report is submitted, a unique report ID is displayed and must be stored in a secure location. This ID gives you access to log in and reopen the review. You can start an anonymous dialog, send any documentation and answer in-depth questions from the admin team. Akurat encourages the whistleblower to log in regularly after the report has been submitted to answer any follow-up questions.

Please refer to the system user manual for a detailed review of the notification process.

How are reports processed?

The reports are processed by Akurat’s admin team.

The process is as follows:

• The admin team will notify the whistleblower that the report has been received within 7 days.
• The admin team assesses and categorizes the complaint and conducts an initial investigation. During this phase, the admin team may need more information or documentation from the whistleblower. The team will start an anonymous dialog with the whistleblower through the system.
• The processing of the notification is initiated and organized according to the nature of the notification. Initially, the case is handled internally. Cases of a particularly serious nature, or which require it, will be passed on to the police for further processing.
• The whistleblower is informed of what has been done in the case within 3 months of receiving the report. If the case is long-term, the whistleblower is updated on an ongoing basis.
• Any personal data in the notification is processed, cf. Akurat’s privacy policy to ensure compliance with personal data legislation.
• When the notification is no longer relevant, it is deleted from the system.

Retaliation

Part of the directive states that whistleblowers should not be penalized for coming forward with information. This way, the whistleblower doesn’t have to worry about future career and personal life consequences as a result of the report. Therefore, if the report is relevant under the Whistleblower Directive, the whistleblower cannot be penalized by Akurat after the report has been filed.

This includes the following penalties (Retaliation):

• Notice of termination
• Suspension
• Downgrading
• Failure to promote
• Change in working hours and tasks
• Decrease in salary
• Intimidation, harassment and social exclusion in the workplace

Akurat’s whistleblower policy is intended to create greater openness and security for the individual employee or other stakeholders.

Safety and security

The system uses a number of security measures to protect you as a whistleblower. Some of these include:

• Full encryption throughout the entire process
• ISO 27001 certified (information security)
• ISO 27701 certified (GDPR compliance)
• ISO27001 accredited servers in Europe
• Schrems II-compliant
• SSL technology
• Shield and WAF at application level
• Two-factor authentication at administrator level
• Redundancy at both application and database level
• Architecture built on the latest technology
• Continuous AI monitoring
• No IP logging

Questions and answers

Questions about Akurat’s whistleblower program can be directed to: 9641 1111 or mail@akurat.dk