HKScan Fair Way Whistleblowing Channel

HKScan is committed to operating honestly and adhering to high standards of ethical responsibility. The same is also expected from all its partners.

To safeguard its ethical commitment and pre-emptively mitigate any associated risks, HKScan has adopted a channel enabling reporting of any suspected breaches of good conduct. The report can be given by name or anonymously. HKScan Fair Way whistleblowing channel is an important tool helping the company to ensure ethical conduct throughout the company’s operations.

Fair Way channel is intended for reporting suspected cases of unethical behavior in HKScan’s business. This applies to suspected violations of the law or other official regulations, deviations from HKScan’s Code of Conduct or other policies or other improprieties as further described in the country specific Fair Way Channel pages.

Whistleblowing may include:

• questionable or suspected improper accounting or auditing practices;
• suspected violations of HKScan’s Code of Conduct, policies and guidelines;
• suspected breaches of financial market rules and regulations governing listed companies, and
• suspected infringements of any other laws or regulations that govern HKScan’s operations.

For further information on matters which shall typically be reported as whistleblowing matters, please see the country specific Fair Way Channel pages.

All whistleblowing reports are processed confidentially

HKScan Fair Way channel is a fully confidential channel intended for anyone who wishes to raise concerns regarding the company or its conduct. The system fulfils high standards of data protection and information security. The report can be given by name or anonymously. To guarantee the complete anonymity of individuals raising their concerns, the system is maintained by an external service provider.

Reporting and Investigation Procedure

HKScan suggests that employees, trainees, persons in management, supervisory or other administrative positions within the company consider if it is more appropriate to share their questions, concerns, suggestions and complaints, e.g. related to their own personal situation, primarily with their supervisor or other internal regular channels or by contacting HKScan Head of Risk Management and designated Senior Legal Counsel via email fairway@hkscan.com. Please exercise caution when sharing information via email. If your concerns or questions may reveal sensitive information about an individual or the business of HKScan, please use alternative communication channels, e.g., by setting up a meeting with your local supervisor or HR manager.

This also applies to external stakeholders, such as shareholders, candidates for employment, trainees, individuals who otherwise conduct work under HKScan’s supervision and control, consultants, contractors, subcontractors, individuals having self-employed status, volunteers and other persons working in supervision or management of contractors, subcontractors or suppliers and customers, consumers and producers or individuals who formerly have been in any of the mentioned roles and obtained the relevant information at that time. All these individuals are encouraged to share the questions, suggestions and complaints with appropriate HKScan personnel, such as their regular contact person within HKScan, or other HKScan’s regular reporting channels available from time to time.

However, if HKScan’s employee or other above-mentioned stakeholder feels that reporting via regular communications channels is not possible on whatever reason, or where a report concerns a whistleblowing matter, it is recommended that he/she reports the questions, suggestions and complaints via HKScan Fair Way Channel. This in order to enjoy the full protection under applicable whistleblowing legislation.

If a person shares his concerns to supervisor or through other channels and not as whistleblower’s report, he/she will not or might not be considered as whistleblower and thus will not or might not be entitled to rights and guaranties as provided for in the law.

When Concerns are reported via HKScan Fair Way Channel, a person can choose at his/her sole discretion to report Concerns to HKScan anonymously or by name, whichever reporting practice they prefer. HKScan shall at all phases of reporting respect the anonymous reporting process and guarantee the confidentiality of the process. Concerns can be reported in English and in the local languages of the countries in which HKScan Group companies are active. Head of Risk Management and designated Senior Legal Counsel of HKScan (or other responsible persons as specified in the country specific Fair Way Channel page) actively communicate the reporter about investigation progress and results to the extent possible and according to local legislation requirements.

Applicable whistleblowing legislation shall always be strictly observed, especially concerning the privacy of persons reporting any Concerns and suspected persons.

Head of Risk Management and designated Senior Legal Counsel of HKScan shall be responsible for investigating and assessing all Concerns reported to HKScan via Fair Way Channel, except where the country specific Fair Way Channel page states otherwise. Internal and/or external resources may assist in the investigation and assessment process when needed. Based on the investigation and assessment, Head of Risk Management and designated Senior Legal Counsel (or other responsible persons as specified in the country specific Fair Way Channel page) take matter into the right decision-making board. All reported incidents are reviewed anonymously with HKScan employee representative (EWC) and SVP HR. Decision-making board decides on the corrective actions. Relevant business owners are responsible for taking the corrective actions. Head of Risk Management and designated Senior Legal Counsel (or other responsible persons as specified in the country specific Fair Way Channel page) follow-up that corrective actions have been duly taken.

Head of Risk Management and designated Senior Legal Counsel (or other responsible persons as specified in the country specific Fair Way Channel page) regularly report to the HKScan Audit Committee of Board of Directors and Top Management on reported Concerns, outcomes of the investigations and possible actions taken.

Guarantee of no retaliation or mistreatment for reporting Concerns

These Guidelines are intended to encourage and enable managers, employees and other stakeholders to raise suspicion of misconduct so that HKScan can investigate and correct inappropriate conduct and actions. With this goal in mind, no employee or other person who in good faith reports any Concern shall be subject to retaliation or any kind of mistreatment due to the reporting action itself. Reporter is protected against retaliation by applicable legislation.

A manager, employee or other stakeholder who retaliates against someone who has reported a suspected violation may be subject to disciplinary procedure or other applicable process in accordance with the applicable legislation.

Every person subject to reporting should be treated equally, fairly and with respect for the rights of the individual. No one shall be held guilty of any offense before the issue has been investigated and every individual has a right to defense him/herself against any accusations.

Data retention and secure storage

HKScan shall retain a copy of all reported Concerns, investigation reports and all relevant documentation thereof. Applicable legislation shall be followed for the period of retention for all the records archived by HKScan. All data is saved into a secure storage.

HKScan Fair Way Team Contact Information

For more information about HKScan Fair Way and detailed instructions for submitting a report, please visit here: HKScan Fair Way channel.

You can communicate or confidentially consult prior to submission of report with HKScan Head of Risk Management or designated Senior Legal Counsel via email fairway@hkscan.com. Please exercise caution when sharing information via email. If your concerns or questions may reveal sensitive information about an individual or the business of HKScan, please use alternative communication channels, e.g., by setting up a meeting with your local supervisor or HR manager.

Country specific detailed information is given on the country specific Fair Way Channel pages.

HKScan Fair Way Statistics

2022
- Number of reports submitted and examined: 22
- Number of reports forwarded to competent authorities: 0
- Amount of resources allocated to the support of the whistleblowing channel annually: Mainly 2, case by base additional internal or external resources used
- Other information related to the submission and examination of reports:

2021
- Number of reports submitted and examined: 11
- Number of reports forwarded to competent authorities: 0
- Amount of resources allocated to the support of the whistleblowing channel annually: Mainly 2, case by base additional internal or external resources used
- Other information related to the submission and examination of reports:

2020
- Number of reports submitted and examined: 9
- Number of reports forwarded to competent authorities: 0
- Amount of resources allocated to the support of the whistleblowing channel annually: Mainly 2, case by base additional internal or external resources used
- Other information related to the submission and examination of reports:

2019
- Number of reports submitted and examined: 10
- Number of reports forwarded to competent authorities: 0
- Amount of resources allocated to the support of the whistleblowing channel annually: Mainly 2, case by base additional internal or external resources used
- Other information related to the submission and examination of reports:

2018
- Number of reports submitted and examined: 24
- Number of reports forwarded to competent authorities: 0
- Amount of resources allocated to the support of the whistleblowing channel annually: Mainly 2, case by base additional internal or external resources used
- Other information related to the submission and examination of reports:

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