Whistleblower policy for the JPS Marselis Group

Background and purpose

The JPS Marselis Group has set up an internal, Group-wide whistleblower scheme in accordance with EU’s Whistleblower Directive and national whistleblower legislation applicable to the individual Group companies. The whistleblower scheme is operated by JPS Marselis ApS, who has appointed the Group’s legal function as its internal whistleblower unit.

The whistleblower scheme applies to all companies in the JPS Marselis Group, regardless of whether the companies are required by law to set up a whistleblower scheme or not.

The JPS Marselis Group whistleblower scheme allows employees, customers, suppliers, partners, and other stakeholders connected to the companies of the JPS Marselis Group, acting in good faith and without risk of reprisal, to report suspicions or specific knowledge of violation of EU law, serious offences or other serious matters at the JPS Marselis Group.

The JPS Marselis Group has an open and dialogue-based company culture, where everyone is free to speak openly about detected irregularities, unacceptable behaviour, or suspicions of anything illegal happening. The whistleblower scheme must therefore be viewed as supplementing going to the management or using other channels of communication to report matters to which you would like to bring attention.

This policy details when you can report using the whistleblower scheme, what you can report about, how a report is handled, rights of the whistleblower and the subject of the report etc.

Who can report information

The whistleblower scheme can be used by current or previous employees of any JPS Marselis Group company. It can also be used by customers, suppliers, partners and other stakeholders connected to a JPS Marselis Group company.

Who you can report

Under the whistleblower scheme, you can report matters involving employees or other persons connected to a JPS Marselis Group company, such as board members, shareholders, consultants, suppliers or external partners.

You can also report matters, even if the matter itself cannot be attributed to any one individual, but is, for example, due to underlying system failure at the JPS Marselis Group.

Matters that you can report

You can report violations of EU law, serious offences and other serious matters.

Your report must be based on a reasonable suspicion, or genuine knowledge of, actual or potential rule-breaking in (for example) the following areas:

• Breaking of rules regarding product safety and conformity, transport safety and consumer protection.
• Criminal offences, such as misuse of financial resources, theft, fraud, embezzlement, bribery, and forgery of documents.
• Serious or repeated breaches of legislation, e.g. in relation to health and safety at work or environmental rules.
• Serious or repeated breaches of significant internal guidelines, e.g. guidelines for business trips, gifts, and accounting.
• Serious conflict affecting individuals in the workplace, e.g. threatening behaviour, physical violence, sexual harassment, or other serious harassment.

The list of examples above is not exhaustive. If you are unsure whether or not a matter should be reported, we encourage you to report it.

The whistleblower scheme cannot be used to report trivial situations or information about (for example) breaches of internal guidelines concerning sick leave, smoking, or alcohol. If rule-breaking is systematic, it may become necessary to report these or other less serious situations under the whistleblower scheme, however.

Other matters such as bullying – except for criminal behaviour (e.g. defamation, slander etc.) – dissatisfaction with salary or ordinary collaboration issues are not to be reported via the whistleblower scheme, but must instead be reported through the normal communication channels in the JPS Marselis Group; e.g. management, HR, the health and safety organisation or union representative.

You can, however, report serious harassment, sexual harassment, and serious collaboration issues.

How to report

The Group-wide online form at jpsmarselis.dk/whistleblower must be used for reporting. All Group company websites contain a link to the Group-wide online form. For reports concerning Hornbaek Baltic AS, reports can, however, also be made using the specific Hornbaek Baltic AS online form at Hornbaek Baltic AS’ website. If you make a report concerning Hornbaek Baltic AS using the specific Hornbaek Baltic AS online form at Hornbaek Baltic AS’ website, Hornbaek Baltic AS will forward the report to the JPS Marselis Group’s internal whistleblower unit for handling in a centralized manner in accordance with this policy.

The report can be made anonymously or non-anonymously. For us to be able to investigate a reported matter as closely as possible, we ask that you provide as detailed a description of the matter as possible.

Procedure when a report is received

When the whistleblower submits his/her report using an online form, the system automatically generates an acknowledgement to confirm receipt, which will be displayed electronically and can also be printed.

All reports are handled and investigated by the Group’s internal whistleblower unit. Within 7 days of the report being made, the Group’s internal whistleblower unit will assess and decide whether or not the matter is recognized as falling within the scope of the whistleblower scheme.

If the matter falls within the scope, the Group’s internal whistleblower unit will launch the necessary investigations and make suitable recommendations in this regard; further details below.

If the matter does not fall within the scope of the whistleblower scheme, it will be dismissed.

If the whistleblower has provided means of contact, he or she will be informed of the decision within 3 days of the decision being made. If the report is dismissed, and if relevant, the whistleblower will additionally receive guidance on who to contact within the JPS Marselis Group instead to discuss the matter in question.

Investigation of a matter

When the Group’s internal whistleblower unit receives a report that falls within the scope of the whistleblower scheme, it will investigate the matter and, if necessary, collect additional information about the matter internally in the relevant Group company or companies.

On that basis, the Group’s internal whistleblower unit will prepare a report, outlining recommendations to the management of JPS Marselis ApS.

The Group’s internal whistleblower unit shall only disclose the whistleblower’s identity in its investigation and report if the whistleblower gives his/her consent. At the request of the prosecution service, administrative proceedings authorities or on the basis of a court decision, and without the whistleblower’s consent, the Group’s internal whistleblower unit may, however, disclose information about the identity of the whistleblower to the relevant authorities. Unless the authorities have advised the Group’s whistleblower unit that informing the whistleblower will jeopardise relevant investigations, inquiries or court proceedings, the internal whistleblower unit shall inform the whistleblower in advance of the disclosure. The identity of a whistleblower who provides a false report in bad faith will not be protected. Other information in the report that does not reveal the whistleblower’s identity shall only be disclosed as part of the follow-up after the report, or to deal with an offence specified in the report.

Against the background of the whistleblower unit’s report and the recommendations, the management of JPS Marselis ApS – if relevant, together with the management of the Group company/companies to which the report relates – will make a decision on which measures and action to take, whether launching internal investigations, reporting to the authorities or taking the actions required pursuant to employment law or contract law.

Duty of confidentiality

The Group’s internal whistleblower unit and the individuals who are involved in the investigations and in processing the report are subject to a special statutory duty of confidentiality covering the information in reports.

This special duty of confidentiality applies exclusively to information in disclosures. If a case against the person or persons reported about needs to be opened as a result of a report, other information collected in connection with this will not be covered by the special duty of confidentiality.

Anonymity and protection of the whistleblower

The report can be anonymous or not. The possibility of the whistleblower’s identity being deduced from the information in the disclosure cannot be ruled out, even when whistleblowing is done anonymously. If legal proceedings are brought against the individual who has been reported, the whistleblower may be called as a witness in the case, at which point anonymity will be forfeited.

Reports about certain matters can be difficult to investigate in great depth without the whistleblower revealing his/her identity and giving up his/her right to remain anonymous. Whether this happens is the whistleblower’s own decision. Whether this happens is the whistleblower’s own decision.

The whistleblower scheme protects the whistleblower against any form of reprisal or threatening behaviour or attempts at reprisals that happen as a result of the whistleblower making a report. Reprisals are to be understood as any form of unfavourable treatment or repercussion that happens in response to a report, e.g. suspension, dismissal, demotion or non-promotion, transfer of tasks, redeployment, pay cuts, disciplinary measures, coercion, intimidation, harassment and discrimination. e.g. suspension, dismissal, demotion or non-promotion, transfer of tasks, redeployment, pay cuts, disciplinary measures, coercion, intimidation, harassment and discrimination.

Any reprisal by an employee of a JPS Marselis Group company may have repercussions for the individual in question under employment law and/or lead to disciplinary action.

The content of the whistleblower’s disclosure must be bona fide, as being named in a disclosure can have major repercussions. Due process under civil law, criminal law or employment law can be applied to the whistleblower, and/or disciplinary measures enforced against him/her, should it be proven that the whistleblower’s report was knowingly misleading, e.g. in case of harassment.

Ongoing communication

The Group’s internal whistleblower unit handles communication with the whistleblower. Communication is only possible if the whistleblower has provided contact details. The Group’s internal whistleblower unit will decide whether ongoing communication is carried out via email or telephone. At the request of the whistleblower, an in-person meeting with the Group’s internal whistleblower unit must be arranged within a reasonable time after the internal whistleblower unit has received the report.

The whistleblower can expect feedback from the Group’s internal whistleblower unit as soon as possible, and, as a general rule, no later than 2 months from the day on which the internal whistleblower unit decides that the report falls within the scope of the whistleblower scheme. As far as possible, the feedback shall include information about any action taken or anticipated and an explanation why those specific actions have been chosen. It may not be possible to share certain information with the whistleblower, e.g. due to a statutory duty of confidentiality or GDPR. It may not be possible to share certain information with the whistleblower, e.g. due to a statutory duty of confidentiality or GDPR.

If the circumstances of the matter entail that it is impossible to provide conclusive feedback within the 2-month timeframe, the whistleblower will be notified of this and also informed about when further feedback can be expected.

Confidentiality

The whistleblower scheme has been devised and is managed in a way that ensures confidentiality around the identity of the whistleblower and those who might be named in a report.

The system used to support the online forms for reports does not log IP addresses. Access to any information relating to reports is restricted. Access to any information relating to reports is restricted.

Registration of reports and processing of personal data

The Group’s internal whistleblower unit registers, and stores reports received, as well as other information and materials collected as part of the investigation of the matter that has been reported.

Personal data policy – whistle-blower scheme outlines in more detail how the JPS Marselis Group companies process personal data in connection with information disclosed under the whistleblower scheme.

What is made known to the individual(s) named in the report

Once the Group’s internal whistleblower unit has investigated a report, and all relevant evidence has been secured, the Group’s internal whistleblower unit will notify the individual being reported of the report. If the investigation has not disproved the report, the individual being reported will also receive the following information:

1. The conduct that he/she is suspected of;
2. Who is involved in the investigation of the report;
3. His/her possible access to the information in the report and right to comment on it, and
4. That the report may be forwarded to the police and other public authorities

Any third party named in the report will also be notified.

If it is obvious that a report is unfounded, does not fall within the scope of the whistleblower scheme or cannot be processed for other reasons and is therefore dismissed by the Group’s internal whistleblower unit, the Group’s internal whistleblower unit will inform the individual being reported that the report has been received and dismissed and do so within a reasonable timeframe and, at the latest, within one month.

Unless expressly stated otherwise in law, the whistleblower’s identity will only be disclosed to the individual being reported if the whistleblower has knowingly made a false disclosure.

Disclosure to external whistleblower schemes

As an alternative to making a report under the JPS Marselis Group whistleblower scheme, it is possible to make a report under external whistleblower schemes provided by the authorities.

For making reports on the JPS Marselis Group’s Danish companies, the Danish authorities provide information about the external whistleblower schemes available in Denmark at whistleblower.dk.

For making reports on Dennerle Plants GmbH and Carmen Damer GmbH, the German authorities provide information about the external whistleblower schemes available in Germany at bundesjustizamt.de and bkms-system.net.

For making reports on Hornbaek Baltic AS, the Latvian authorities provide information about the external whistleblower schemes available in Latvia at trauksmescelejs.lv.

The JPS Marselis Group encourages you to use the Group’s internal whistleblower scheme if you think that the situation can be dealt with by the JPS Marselis Group.

Updated March 2025