Euro Pool Group - whistleblower policy for third parties

Euro Pool Group is committed to do business honestly, with integrity and in a sustainable way. A part of this is creating a culture of honesty and openness, where all interested parties at Euro Pool Group who have concerns about a (suspected) violation of applicable laws and regulations or other misconduct can raise such concerns.

This policy applies to all (current and former) suppliers, service providers, contractors and sub-contractors and their respective employees of Euro Pool Group. Employees, interns, trainees, and volunteers of Euro Pool Group are covered by their own internal whistleblower / SpeakUp policy and as such should refer to this when raising a concern.

Euro Pool Group encourages all interested parties to report any suspected or known improper conduct (known or suspected) to their contact at Euro Pool Group or the management of Euro Pool Group initially, as in most cases this should result in your concern being satisfactorily addressed. Where this is not appropriate for any reason, you can report your concerns to the Group Compliance Officer of Euro Pool Group:

Euro Pool Group
Attn. Group Compliance Officer
P.O. Box 1887
2280 DW Rijswijk

T: +31 (0)70 301 4173

This policy covers any concerns about (i) conduct that is in breach of the (EU) laws or regulations, including in the areas of product safety (incl. legality, quality or integrity) and compliance, transport safety, damage to the environment, food safety, public health, consumer protection, privacy and personal data, (ii) possible fraudulent or corrupt conduct, and/or (iii) breaches of competition laws.

In case you have an enquiry or concern which does not relate to illegal or unethical behaviour or wrongdoing, please discuss this with your regular contact at Euro Pool Group.

All concerns will be treated confidentially and if you ask for your identity to be protected, it will not be disclosed without your consent. All disclosures will be treated in a confidential and sensitive manner. Investigations into reported misconduct will be conducted in a fair and objective manner. The filing of a report does not guarantee that the matter will be formally investigated. All reports will, however, be assessed and considered by Euro Pool Group to determine if and if so, how, the conduct should be investigated. When you file a report, you will receive an acknowledgement of receipt within seven (7) days after which Euro Pool Group received the report, provided your identity, and contact details are known. Where reasonable and appropriate, a progress update will be provided. In any case, you will be informed of the status of the investigation and actions taken (if any) within three (3) months after Euro Pool Group received the report.

All suppliers, service providers, contractors and sub-contractors of Euro Pool Group and their respective employees who report their concerns in good faith will not suffer detrimental treatment in anyway, regardless of the outcome of the investigations. Deliberately raising false or malicious concerns, however, will be reviewed extremely seriously by Euro Pool Group.