Whistle Blowing Policy DANX Group A/S

1. The object of the Whistleblowing Policy

DANX Group A/S (“DANX”) wishes to encourage an open dialogue on all issues related to DANX and its subsidiaries’ ("DANX Group”) business methods, compliance with DANX’ poli-cies or issues which are considered illegal.

The purpose of DANX Group’s whistleblower system is further to ensure a safe environment in which employees within DANX Group have the confidence to speak out about reprehensi-ble practices without fear of repercussions. Thus, the whistleblower system is intended to con-tribute to ensuring that serious errors and omissions are detected and to the widest extent possible prevented.

The whistleblower system is a supplement to the direct and daily communication at the work-place regarding errors and unsatisfactory conditions, etc.

Reports are filed electronically through the whistleblower system via a web portal, Safe2Whistle, which may be accessed via the internet

2. Who can report and where?

All employees within DANX Group, including drivers and haulage contractors as well as members of DANX Group’s management board and members of the board of directors are covered by the whistle blower system and can as such report to the system.

3. What to report

The whistleblowing system is solely for the reporting of serious violations subject to the Danish Whistleblower Protection Act. Thus, you may file a report to DANX Group’s whistleblowing system regarding

  • violations of specific areas of the EU law

  • serious offences and other serious matters

In regard to violations of specific areas of the EU law, you may e.g., file a report regarding

  • Violations concerning the protection of the environment as well as product safety and compliance. For other areas of relevant EU law, which may be reported about, please refer to article 2 of the EU Directive (EU) 2019/1937 of 23 October 2019 on the pro-tection of persons who report breaches of Union law.

By other serious offences and other serious matters, reports may e.g., concern

  • Punishable offences, e.g., abuse of funds, theft, fraudulent misrepresentation, embez-zlement, fraud, bribery, etc.

  • Serious or repeated violations of legislation, including e.g., rules pertaining to the envi-ronment, unsafe working environment, road traffic legislation etc.

  • Serious or repeated violations of material internal guidelines, e.g., on business trips, gifts, financial reporting, etc.

  • Serious workplace conflicts, e.g., in the form of sexual harassment or other serious harassment.

The whistleblower system cannot, in general, be used for expressing dissatisfaction with sala-ry levels, minor offences such as violations of guidelines regarding smoking and drinking of alcohol and less serious workplace conflicts and disagreements.

4. How to report

If you file a report, the information listed below will generally be useful in connection with fur-ther investigation of the issue:

  • A description of the issue in question, including date, place, and the name(s) of the person(s) involved

  • Any documentation or evidence concerning the violation or other information which may assist the investigation

It is up to you whether you want to file the report in your own name or anonymously.

If you choose anonymity, it is important that you do not state your name anywhere in the re-port. In addition, you should be aware that your identity might be inferred from the information you have provided in the report.

DANX Group may be under an obligation to make the report available to the persons affected by it or by the resulting measures.

5. How we handle the issue

As mentioned above, reports to the whistleblowing system can be made electronically via a web portal, Safe2Whislte, which is accessible via the internet https://report.whistleb.com/en/danxgroup.

Bech-Bruun is the data processor for purposes of managing the whistleblower system. The purpose of using an external party is to ensure impartiality and objectivity in the processing of the reports.

As external administrator of the whistleblowing system, Bech-Bruun receives all reports and will begin by filtering out the reports that do not fall within the scope of the system, cf. clause 3. Filtered out reports are to be processed through the ordinary channels of communication. You will in this regard be encouraged to direct your report to a relevant person, e.g., your im-mediate manager or your manager’s superior.

Reports falling within the scope and purpose of the whistleblower system will be forwarded to DANX Group’s whistleblower unit, who will process and investigate the report. Bech-Bruun will be notified about the outcome of the investigation and will assess whether the matter may be considered as closed, or whether the report should give rise to additional investigations.

The whistleblower unit at DANX Group consist of a manger within HR and Finance respec-tively.

Reports concerning a member DANX Group’s whistleblower unit will be processed by Bech-Bruun in collaboration with the remaining members of the whistleblower unit who are not dis-qualified in regard to investigate the specific case. Reports concerning the management board or members of the board of directors of DANX Group will be processed by Bech-Bruun in collaboration with the chairman of the board of directors of DANX. Reports concerning the chairman of the board of directors of DANX will be processed by Bech-Bruun in collaboration with two members of the board of directors of DANX who are not disqualified in the relevant case.

No later than 7 days after your report has been received in the whistleblowing system, you will receive a confirmation of the receival of your report. As a main rule, you will receive a notifi-cation concerning the closure of your report no later than 3 months from receiving this con-firmation. If the processing of your report requires longer than 3 months, you will receive a notification regarding the reason why further investigation time is necessary. You will as a main rule, within the limits of relevant legislation, receive information about the outcome of your report.

All communication between you and Bech-Bruun will take place over the whistleblower portal. Thus, it is important that you follow your report on the whistleblower portal if you want to re-ceive confirmation of receipt of your report, a reason for why you report require longer pro-cessing time and if you want to receive a notification about the outcome of the investigations of your report, since you will not receive any email pertaining to the above listed information.

6. Protection of the whistleblower

DANX does not tolerate harassment, vengeful actions or other types of sanctions against any person who in good faith files a report.

Even though you have not made an anonymous report, your identity will be kept confidential to the extent possible, considering DANX’s need to make a thorough investigation. However, it may be necessary to disclose information about your identity, for instance if the issue is reported to the police. In such case you will receive information beforehand.

You may not knowingly report incorrect or misleading information through the whistleblower system. Persons who report in bad faith are not protected by this whistleblowing policy and may be subject to employment law sanctions, including possible dismissal.

6. Protection of the whistleblower

DANX does not tolerate harassment, vengeful actions or other types of sanctions against any person who in good faith files a report.

Even though you have not made an anonymous report, your identity will be kept confidential to the extent possible, considering DANX’s need to make a thorough investigation. However, it may be necessary to disclose information about your identity, for instance if the issue is reported to the police. In such case you will receive information beforehand.

You may not knowingly report incorrect or misleading information through the whistleblower system. Persons who report in bad faith are not protected by this whistleblowing policy and may be subject to employment law sanctions, including possible dismissal.

7. Duty of confidentiality

Bech-Bruun is together with DANX Group’s whistleblower unit subject to a special duty of confidentiality. Further, any person who is involved in the investigations of a report will be sub-ject to the same special duty of confidentiality in regard to any information that has or is sub-ject of the investigation of the report received through the whistleblowing system.

8. Notice to the reported person and to other persons

If information about you is reported in the whistleblower portal, and the report falls within DANX Group’s whistleblower system, you will as a general rule, not receive any information about the processing of your personal data.

If, on the other hand, the report does not fall within DANX Group’s whistleblower system, you will be informed of the processing of your personal data in accordance with the rules of the Data Protection Regulation and the Danish Data Protection Act.

9. Data protection

The processing of personal data in connection with a report received in the whistleblowing system will be on the basis of section 22 of the Danish Whistleblower Protection Act, accord-ing to which processing of personal data subject to articles 6, 9 and 10 of the General Data Protection Regulation may take place if the processing of the personal data is necessary to investigate a report received in the whistleblowing system established in accordance with the Danish Whistleblower Protection Act.

The General Data Protection Regulation and the Danish Data Protection Act will apply to any further processing of personal data in the whistleblower system.

DANX Group A/S, Vejleåvej 9, 2635 Ishøj, Denmark, CVR number 28665210 is the data con-troller for purposes of managing the whistleblower system.

For further information with regard to the processing of personal data please refer to the Pri-vacy policy for employees and external parties https://www.danx.com/AboutDanx/gdpr.


Please contact Lise Lauridsen +45 7227 3635, Bech-Bruun, if you have any questions about the Whistleblowing Policy.

You may also file a complaint with the Danish Data Protection Agency (Datatilsynet), B Carl Jacobsens Vej 35, 2500 Valby,dt@datatilsynet.dk.

If you do not feel safe using DANX Group’s whistleblowing system, or due to other reason feel safer using and external whistleblowing system, you may file a report via Danish Data Protection Agency’s external whistleblowing system, in which you may file a report either in writing or orally. The Danish Data Protection Agency’s whistleblowing system is available via www.datatilsynet.dk

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