Purpose

Our whistleblower policy establishes the framework for TeeShoppen's whistleblower scheme, which can be used in addition to TeeShoppen's usual reporting channels to report serious matters, including suspicion or knowledge of illegal, unethical or unregulated behavior.

The scheme is currently established on a voluntary basis and is designed to comply with the rules set out in the law on the protection of whistleblowers to the greatest extent possible.

Who can make a report?

TeeShoppen's whistleblower scheme can be used by the following groups:

• - TeeShoppen's employees

• - Self-employed individuals (with whom TeeShoppen collaborates)

• - Members of the Board of Directors

• - The Executive Board

• - Volunteers in TeeShoppen

• - Paid or unpaid interns in TeeShoppen

• - Individuals who work under the supervision and management of TeeShoppen's contractors, subcontractors, and suppliers

• - Individuals who make reports or disclosures of information that they have accessed in the course of their work for TeeShoppen, which has since ended

• - Individuals whose employment with TeeShoppen has not yet begun, who report violations that they have become aware of during the employment process or other pre-contractual negotiations.

How is the report made?

The report can be made in writing or verbally through the whistleblower portal, which can be accessed on TeeShoppen's website. Our system informs and guides you on matters of importance in assessing the report.

What can be reported?

You can use the whistleblower scheme to report all serious violations of the law and other serious matters. For example, suspicion or knowledge of illegal, unethical or unregulated behavior, including bribery and corruption, misuse of financial resources, theft, fraud, embezzlement, financial crime in general, and breaches of personal data security, serious harm to the environment, conflicts of interest, cases of unwanted sexual attention (sexual harassment) or other serious harassment, as well as serious or repeated violations of the law in general.

You can also report violations of EU law covered by the scope of the whistleblower directive. This may include violations in public procurement, financial services, product safety and compliance, and environmental protection.

In each case, we will make a specific assessment of whether the report falls within the scope of the scheme. The report will fall within the scope of the scheme if it falls within the scope of the applicable rules on the protection of whistleblowers in Denmark.

If you are an employee, we would like to remind you that dissatisfaction with your employment, such as salary and management style, and other contractual terms should not be reported through the whistleblower scheme as a general rule. Such matters should instead be addressed through normal channels, including your immediate supervisor, your union representative and/or HR.

Reports must be made in good faith. This means that you must have reasonable grounds to believe that the information reported is correct at the time of the report and that the information falls within the scope of the scheme. It also means that the scheme must not be used to report deliberately false information.

Handling of reports

TeeShoppen screens any reports made through the whistleblower scheme.

As a reporter, you will receive an acknowledgment of receipt of the report as soon as possible and no later than seven days after your report, either via the whistleblower portal or the contact information you provided. If you make an anonymous report, you will only receive confirmation through the whistleblower portal if you save the access code received in connection with the report.

During screening, it is assessed whether you as a reporter and the reported matter are covered by TeeShoppen's whistleblower scheme. If it turns out that this is not the case, the report will not be further processed under the scheme, and you will be notified of this.

If the initial screening shows that you and the reported matter are covered by the whistleblower scheme, the report will be subject to an investigation, the extent of which depends on the specific circumstances of the case. The further investigation is usually carried out by TeeShoppen's whistleblower unit, which is established for this purpose and composed of impartial individuals.

As a reporter, you will receive feedback on the status of the case within three months, including any follow-up on the report that may have been conducted. You will receive feedback through the whistleblower portal or the contact information you provided. If you make an anonymous report, you will receive feedback through the whistleblower portal.

Anonymity and protection of the reporter

You can freely choose whether to make a report anonymously or with the disclosure of your personal contact information.

If you choose to make an anonymous report, your personal information will generally not be processed. However, if you provide information in connection with your report that enables TeeShoppen to identify you, TeeShoppen may process that information, regardless of whether you have otherwise made an anonymous report.

With an anonymous report, you can choose whether to make yourself available for any further investigation by saving the access code received in connection with your report. The access code allows you to access and follow up on your report in the whistleblower portal, including communicating with TeeShoppen's whistleblower unit. We encourage you to save the access code as it may be difficult for TeeShoppen to conduct an investigation without further information from you.

If you choose to disclose your identity in connection with a report covered by the whistleblower scheme, TeeShoppen's whistleblower unit will keep your identity confidential to the fullest extent possible. This means that your identity will generally not be disclosed to people outside the whistleblower unit. However, information about your identity may be disclosed if you expressly consent or if required by law. For example, your identity may be disclosed to another public authority if necessary to address the reported matter or to ensure the affected persons' right to defense, as well as to external advisers such as a lawyer or auditor for further investigation of the reported matter. You will be notified before any disclosure to the extent possible in light of the specific case processing.

A reporter who, in good faith, reports serious matters covered by the whistleblower scheme cannot be met with retaliation of any kind as a result of the report.

If you consciously report incorrect information, it can have negative consequences for you, including fines, employment law or contractual consequences.

The reporting system does not log the IP address or machine ID of the computer from which the report is made, and the system does not use cookies. If the computer from which the report is made is owned by TeeShoppen or connected to TeeShoppen's network, there is a risk that the IP address and/or machine ID from which the report was made will be logged in the browser history and/or TeeShoppen log via the logging that occurs in TeeShoppen's IT systems. You can eliminate this risk by making the report from a computer that is not owned by TeeShoppen or connected to TeeShoppen's network.

Protection of the reported individual

The identity of the natural or legal person reported or a natural or legal person associated with that person, such as the person's spouse, will be protected during the processing of the report and will only be disclosed to persons outside TeeShoppen's whistleblower unit if it happens as part of follow-up on a report to prevent violations or is otherwise required by law.

These individuals have the right to an effective defense in cases where the reported information is part of the evidence, and therefore received reports are registered, and information about the reporter's identity can be disclosed in such cases.

Reporting to an external whistleblower scheme

You can freely choose between making a report to this whistleblower scheme or to an external whistleblower scheme. For example, the Danish Data Protection Agency has established an external whistleblower scheme that complements employers' obligation to establish whistleblower schemes. You can read about the procedure for making a report to the Danish Data Protection Agency's scheme on their website: www.whistleblower.dk. Here you will also find a link to the Danish Data Protection Agency's reporting portal, from which you can choose to make your report.

We encourage you to make your report through this whistleblower scheme if the violation can be effectively addressed internally, and you assess that there is no risk of retaliation, so TeeShoppen can quickly and immediately follow up on the reported matter.