Whistleblowing

Introduction to the Thule Group whistleblowing policy

This whistleblowing policy, which is drafted in line with the principles articulated in the Company’s Code of Conduct, is a vital part of the Company’s Corporate Compliance Program.

Employees are often the first to discover misconduct at their workplace, and it is important that an employee who discovers wrongdoing by the Company or any of its employees, consultants, contractors, or suppliers is able to report it without risk of retaliation or discrimination.

The purpose of this policy is to encourage employees to raise concerns about matters occurring within or related to the Company, rather than overlooking a problem or seeking a resolution of the problem outside the Company.

This policy applies to everyone at the Company – all employees, managers, executive officers, and members of the board of directors (all of whom are included in the term “employees” as used in the remainder of this policy).

The Whistleblowing System

In order to allow employees to raise concerns about wrongdoing, the Company has established a whistleblowing system that serves as a contact interface designed specifically for receiving and handling employees’ reports on suspected misconduct.

However, laws and regulations on protection of personal data set limitations on the circumstances under which a company may process information indicating that one of its employees has been involved in suspected misconduct.

For this reason, the whistleblowing system may only be used in the following circumstances:

First, only serious misconduct may be reported through the whistleblowing system. Serious misconduct involves irregularities or improper actions concerning the Company’s vital interests or individuals’ health and safety. This may for example include:

• financial crime and accounting irregularities;
• the offering or acceptance of bribes;
• environmental risks or crimes;
• security vulnerabilities which constitute a risk for employees’ or customers’ health or safety;
• serious forms of harassment or discrimination; or
• violations of the Company’s Code of Ethics.

Second, the whistleblowing system may only be used to the extent that it is justified not to turn to the Company’s standard information and reporting channels, as described in the last section of this policy. This may for example be the case when the reported person is part of the management or the suspected misconduct, for that or other reasons, runs the risk of not being properly handled.

Third, due to limitations under the current data protection regulation in Sweden, the following limitations apply for Sweden only: Only misconduct by persons in a key or leading position within the Company may be reported via the whistleblowing system. This means that only misconduct by the Company’s board of directors, executive officers, or individuals responsible for major purchases or other key business functions may be reported through the whistleblowing system.

The whistleblowing system complements the Company’s internal information and reporting channels and is available for use on a voluntary basis.