Whistleblower Policy for Ambu
– Business Partners, Suppliers and Customers

Ambu requires its employees, and representatives in any way to observe a high standard of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of Ambu, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

This whistleblower policy is intended to encourage and enable all customers, business partners as well as our own employees to raise serious concerns, so that Ambu can address and correct inappropriate conduct and actions. We consequently ask for your help in identifying areas for improvement by reporting concerns about violations of Ambu’s code of conduct, anti-bribery policy or suspected violations of law or regulations that govern Ambu's operations.

Scope

This policy is global and applies to the entire Ambu group, defined as Ambu A/S and associated companies, affiliates of Ambu A/S or any entity that is directly or indirectly controlled by Ambu A/S, or is under common control or ownership with a party no matter the geographical location. The initiative is administered by and on behalf of Ambu A/S as the data controller.

What to report

You are strongly encouraged to take action promptly when faced with non-compliance with any Ambu policy or procedure, such as Ambu’s Code of Conduct or Anti-bribery Policy or any other applicable law or regulation. Examples may include:

  • Financial fraud, criminal offence and other types of inappropriate financial practices or practices that raise questions about Ambu’s accounts, financial reporting, internal controls or auditing practices
  • Misconduct of business practices and our Code of Conduct, which could constitute a conflict of interest. Corruption including payment of bribery or facilitation payments, unethical donations, gifts or entertainment to business partners given by Ambu employees
  • Serious improper management including serious breaches of occupational safety, concerns about environmental pollution, serious issues directed towards an employee, for example, discrimination, violence or sexual assault or serious violation of local policies

It is in the best interest of Ambu that breaches of the Policies and Rules are reported. For this reason, Ambu will not tolerate retaliation against anyone who reports non-compliance with the Policies and Rules, regardless of whether their claim can be substantiated.

Cooperation and investigations

The Whistleblower Hotline is managed by an external Audit Committee, which consists of three members of Ambu’s Board of Directors.

If you wish to raise a concern through the Whistleblower Hotline, you can contact the Audit Committee by sending an email to the following address: w-hotline@ambu.com

You can write in your local language, if you don’t feel comfortable writing in English.

In order to enable the Audit Committee to investigate the matter, you should explain and describe your concern in a reasonably detailed manner. The more information the Audit Committee receives, the easier it will be to initiate an investigation of the matter.

You should not attempt to conduct an individual investigation to determine whether there has been a violation, but you should instead report suspected violations to the Audit Committee like described above.

Please be advised, that the report does not guarantee you anonymity. However, if you choose not to write your name or contact information in the report, the only identifying information is your IP-address and your e-mail account. Ambu will not attempt to use this for identifying purposes by contacting external parties to that effect. Of course, we always encourage you to identify yourself by providing your name and contact information. We will treat your report confidentially and protect your identity internally. Only if a police investigation or other external investigations are needed, we might be required to reveal your name for them to assess all the information in the specific case.

Upon receiving your report, the Audit Committee will – if the chairman of the Audit committee deems that the practice reported is objectionable – assign the internal Whistleblower Workgroup for each reported concern if it is without any risk of conflict of interest. If needed, an independent external investigator may also investigate a concern.

The documentation relating to your report will be kept confidential and safe.

If you have provided your contact information, you will receive an email from the Audit Committee, so you know that they have received your report.

It is important to avoid innocent persons being suspected of irregularities that may constitute violation of the law or possibly misconduct. To this end, you should consider very carefully, whether the practices you intend to report are criticisable, before you contact the Audit Committee.

Are there any country-related restrictions?

The law of some countries imposes specific restrictions on reports, such as what may be reported, or whether a report can be submitted anonymously. These restrictions are incorporated into our Whistleblower Hotline:

  • In Spain, concerns may not be reported anonymously.
  • In France, certain concerns, e.g. discrimination and harassment, may not be reported.

Personal data issues and information

Ambu A/S (HQ), Baltorpbakken 13, DK-2750 Ballerup, Denmark, is data controller of the Whistleblower Hotline. Ambu will process your personal data in accordance with the Danish personal data protection rules and the General Data Protection Regulation (GDPR).

The personal data processed will be stored for as long as needed for the purpose for which it has been collected.

The processing of the above-mentioned criminal offences are necessary for the purpose of pursuing a legitimate interest that clearly overrides the interests of the data subject according to the Danish Data Protection Act and the GDPR.

If a request for access is received, the person will be notified of i) the type of data being processed, ii) the purposes of the processing, iii) the categories of recipients of the data, and iv) any available information as to the source of the data, however, not information about persons having made a report in good faith.

Furthermore, the person has the right to object to the processing and request restriction of the processing of their personal data. In addition, the person also has the right to require us to rectify or erase their personal data, if necessary. Under certain circumstances, they may also request that we provide them with an overview of their personal data in a structured, commonly used and machine-readable format and request us to transmit such data to another data controller.

However, the right of access will not apply if the person's interests in obtaining this information are found to be overridden by essential considerations for public or private interests. The accused individual is only entitled to receive information about him/herself and not about other persons. They are not entitled to receive any information about you, who initiated the process.

If your or the accused person's personal data is transferred to data controllers or data processors which are located in countries outside the EU/EEA, including entities in the Ambu Group, not ensuring an adequate level of data protection, such transfer will be safeguarded by the EU Commission’s Standard Contractual Clauses.

If the outcome of the investigation is that no proof of irregularities has been found, the personal data will be deleted promptly and at the latest within two months after completion of the investigation.

If sufficient proof of irregularities has been found, different periods apply depending on whether legal proceedings are commenced or disciplinary measures are taken against the accused individual or against the person making the accusation in cases of accusations made in bad faith. In practical terms, when the need for documentation of the matter is no longer present, the data will be deleted. Data may also be kept if made anonymous.

You may also contact us regarding any personal data issues by sending an e-mail to: dataprotection@ambu.com and you always have the right to file a complaint with the Danish Data Protection Agency (in Danish “Datatilsynet”), Borgergade 28, 5., 1300 Copenhagen, dt@datatilsynet.dk.

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