ÁñÁ«ÊÓƵ

In line with the ÁñÁ«ÊÓƵ Values and Code of Conduct, the business integrity of ÁñÁ«ÊÓƵ is non-negotiable. ÁñÁ«ÊÓƵ is committed to conducting our business in accordance with the law and high ethical standards.

ÁñÁ«ÊÓƵ has adopted a Speak Up Policy and reporting system that makes it possible for employees, customer, business partners and other stakeholders to report concerns in a secure and confidential manner.

If you are an employee, customer, business partner or other stakeholder and believe there is a breach of the ÁñÁ«ÊÓƵ Code of Conduct, our policies or relevant laws and regulations, we encourage you to speak up and report it. By reporting you are acting in the spirit of our Code of Conduct and Values and helping to protect our business and our reputation.

There are several ways to report a concern. Depending on the nature and seriousness of the concern, you can address your concern first with your supervisor or manager, local Head of People & Culture, local Legal Director or local CFO.

If you wish to report a concern within the scope of the Speak Up Policy, you can report the matter by accessing the Speak Up system. All communication will be anonymous and confidential unless you instruct otherwise. To facilitate investigation of the matter, you are encouraged to identify yourself and explain your concern in sufficient detail.

Concerns relating to your employment terms or local workplace matters such as conflicts with colleagues and managers, disciplinary sanctions, correct and timely payment of wages and benefits are outside the scope of the Speak Up Policy and should normally be reported to your local superior or the local Head of People & Culture and be resolved locally.

If you are not comfortable addressing your concern within the local reporting lines or the matter is not resolved satisfactorily, please use the Speak Up system for reporting your concern.

Investigation process
Your concern made via online or staffed hotline Speak Up system will be screened by an external law firm to safeguard the process from conflicts of interest, before sending the report to the Head of Group Internal Audit or escalating it to appropriate ÁñÁ«ÊÓƵ bodies. 

The Head of Group Internal Audit shall (i) record and acknowledge within 7 days all reports, (ii) consider the seriousness and credibility of the report raised and (iii) proceed accordingly in determining the appropriate action. Some reports may be resolved without requiring investigation. 

The Head of Group Internal Audit may consult your report with the ÁñÁ«ÊÓƵ Business Integrity Committee or the ÁñÁ«ÊÓƵ Audit & Risk Committee and any senior members of management. The Head of Group Internal Audit may also engage external auditors, investigators and/or legal counsel to assist in the investigation and analysis of the results.

Appropriate remedial action will be taken in case an investigation shows violation of ÁñÁ«ÊÓƵ policies and/or laws and regulations. Where legally possible and depending on the circumstances, ÁñÁ«ÊÓƵ will inform you of the action envisaged or taken as follow-up to the report and the reasoning for that follow-up.

Protection ¨C no retaliation against reporters
If you report a concern to ÁñÁ«ÊÓƵ in good faith, we will ensure that there will be no discriminatory or retaliatory action against you as a result of a Speak Up report.

National laws, where applicable and relevant, that may provide better protection for you as a result of the Speak Up report and investigation, will supplement or override this Policy. 

Retaliation means any direct or indirect act or omission which causes or may cause unjustified detriment to the reporter. If you believe you have been retaliated against for reporting or participating in an investigation, you should immediately report such perceived retaliation to the Head of Group Internal Audit (please see contact details below) or by using the Speak Up system. All such reports will be investigated confidentially.

Alternative reporting options: reporting to authorities
If you reside in the EU, you may - instead of reporting to ÁñÁ«ÊÓƵ - report a concern to the local external reporting channel available in your country. The external reporting channel is managed by a local authority in your country permitting reporting similar to reporting internally to ÁñÁ«ÊÓƵ. 

For information on which authority is managing the external reporting channel, please check the Responsible Business Conduct & Speak Up webpage of your country. 

You are encouraged to report concerns to ÁñÁ«ÊÓƵ first.

Personal data
Collection, processing, and any disclosure of personal data submitted via the Speak Up system will be carried out in compliance with applicable data protection laws, including the EU General Data Protection Regulation and the Danish Data Protection Act.