Contents 1 Purpose . 3 2 Responsibilities . 3 3 Scope . 4 3.1 What is DSV’s Whistleblower system, Integrity Line ?. 4 3.2 What can be reported through DSV’s Integrity Line ?. 4 3.3 What concerns and grievances should be reported using other channels? . 5 4 Reporting process. 6 4.1 How can I report concerns through DSV’s Integrity Line ? . 6 4.2 What information is needed to make a report?. 6 4.3 Anonymous reporting. 6 5 Investigations. 7 5.1 How are whistleblowing reports of investigated?. 7 5.2 Time frame . 8 5.3 Confidentiality . 8 6 Resolutions of whistleblowing reports . 9 6.1 Who decides? . 9 6.2 What kind of actions can be taken? . 9 6.3 Appeal of the action/rights according to law . 9 7 The rights of the parties involved in the report. 9 7.1 Protection against retaliation. 9 7.2 Rights of the reporter . 10 7.3 Rights of the accused individual. 10 8 Data protection . 11 8.1 Storing of files . 11 8.2 Destroying of files . 11 9 Questions . 11 Change Control. 12 2
1 Purpose DSV is committed to fostering a culture of integrity, transparency and accountability. This Policy describes the rights and responsibilities DSV and whistleblower reporters have and the process involved in reporting concerns through the DSV Whistleblower system, Integrity Line , its subsequent investigation and data access and retention. This Policy enables actual or suspected misconduct to be raised through the appropriate channels, allowing DSV to objectively investigate any allegations and take appropriate action to remediate any substantiated misconduct. This Policy outlines a set of guiding rules and principles for all DSV employees, the Board of Directors of DSV A/S and external parties on how to report actual or suspected misconduct and alleged violations of law or the DSV Code of Conduct, Guidelines, Manuals and Policies by employees or third parties’ acting on behalf of DSV. Furthermore, the Policy provides the Group Executive Board and the Board of Directors of DSV A/S with an insight of and learn about any wrongdoings and to resolve matters quickly and appropriately. Additionally, the Policy will serve as an efficient tool for the Group Executive Board and the Board of Directors of DSV A/S to efficiently monitor and analyse the categories of incidents reported to identify areas where Policies need to be amended if deemed necessary and relevant. Wherever local laws differ from the provisions of this Policy, the local laws shall take precedence. 2 Responsibilities Group Sustainability & Compliance is overall responsible for the Whistleblower Policy, while the reported concerns falling within the scope of this Policy are handled and investigated by the Investigation Team withing Governance, Risk and Control team in Group Finance (see section 5 and 6). The Board of Directors of DSV A/S oversees the management of the Whistleblower Policy and approves any applicable updates. Local management is responsible for implementing procedures that support the implementation of the Whistleblower Policy. In accordance with the Code of Conduct and Supplier Code of Conduct, DSV employees and external third parties are responsible for complying with the standards set in the Codes, other applicable DSV policies and procedures and an applicable laws and regulations. DSV employees and external parties are therefore encouraged to report concerns or knowledge of actual or suspected misconduct through any internal channel they feel comfortable using. Regardless of the channel used, e.g. direct supervisor, HR, local management, Group Sustainability & Compliance or the Whistleblower System, reporters are under the same obligations and protections as described in this Policy. All DSV employees and external parties are encouraged to be alert and vigilant to situations that could result in misconduct, since any violation of law or the Policies can be extremely damaging to DSV. 3