Stahl Parent B.V.
Whistleblower policy

October 2023

Table of contents
1. Important takeaways of this policy .................................................................................................................................... 3
2. Introduction ..................................................................................................................................................................... 6
3. Definitions........................................................................................................................................................................ 6
4. Information, advice and support for the Employee and the Other Affected Party.................................................................. 8
5. Internal reporting, recording, forwarding and confirming receipt of an internal Report.......................................................... 8
6. Processing the internal report ........................................................................................................................................... 9
7. Conducting the internal investigation ...................................................................................................................... 10
8. Information about outcome ....................................................................................................................................... 11
9. External report and public disclosure ...................................................................................................................... 11
10. Protection .................................................................................................................................................................... 1210.1 Protection of the Whistleblower ......................................................................................................................... 1210.2 Counteracting negative measures for the Whistleblower ................................................................................ 13
10.3 Protection of other parties involved from negative measures ........................................................................ 13
10.4 Internal and external investigation of negative measures for the Whistleblower ......................................... 13
11. Confidentiality ............................................................................................................................................................. 14
12. Reporting and evaluation........................................................................................................................................... 14

For Stahl Parent B.V. and affiliated companies internal use only. Stahl Parent B.V. reserves the right to amend, update or withdraw its corporate policies
without prior notice. Version: October 2023
Page 2

1.

Important takeaways of this policy

When people are unfairly affected by the actions of a company or its employees, grievance or
whistleblower mechanisms can help provide a remedy by offering people a confidential outlet to voice
concerns and report wrongdoing. They also serve as an early warning system for companies and canprovide valuable insights for broader human rights issues.
At Stahl, we want to make a positive contribution to the lives of our employees, customers, business
partners, investors, and society at large. To do so, we seek to maintain a healthy, open dialogue with all
our stakeholders around the world and to develop a mutual understanding with them on relevant topics.
We always encourage employees and other affected parties to proactively come forward with theirconcerns. Our formal Grievance Mechanism/Whistleblower policy is open to all Stahl employees as wellas anyone outside the company. It is a way to raise and discuss issues and complaints in total
confidence. To do a proper investigation of the situation, a good report is needed, as it is difficult toinvestigate anonymous unsubstantiated reports. To meet any concerns about confidentiality, we havealso created a list of “Confidants”, people in the company with whom concerns can be raised at the
local level in each region. A list of these “Confidants” is available at MyStahl.
Any grievance you bring to us will receive full attention. The company will listen, take steps toinvestigate and address the issue, and seek appropriate action with the responsible party.
What should I report?
•••

Suspicious behaviour that may conflict with Stahl's Code of Conduct (e.g. non-compliancewith regard to human rights, fundamental freedoms, environment, safety, health, corruption,bribes, fraud, harassment etc) ;Suspicion of non-compliance with laws and regulations;
Any negative impact on people, communities, or the environment as a result of our activities.

How do I report an issue?
•
•
•

•
•

Through your supervisor;
Through a Confidant (HR) per location as published at MyStahl;
Through any member of the Compliance Committee (Chief Financial Officer, Chief
Compliance Officer and/or the Group Director HR) in person or by email:whistleblower@stahl.com;
By Phone: +31 416689210 (Chief Compliance Officer);
By letter: addressed to the Chief Financial Officer, the Compliance Officer and/or the Group
Director HR.

Stahl will respond timely, as required under laws and regulations.
The Whistleblower who has, in good faith, made a report shall not be affected in any way as a result of
making that report. Stahl employees shall be protected against intentionally filed false reports. An

For Stahl Parent B.V. and affiliated companies internal use only. Stahl Parent B.V. reserves the right to amend, update or withdraw its corporate policies
without prior notice. Version: October 2023
Page 3

employee who intentionally files a false report will be subject to disciplinary measures, as described in
the Stahl disciplinary action policy.
In the following paragraphs you can read more about the formal (technical) procedure. See also theprocess diagram on the next page.
In case you have any questions or remarks about this policy, please do not hesitate to contact the Chief
Compliance Officer.

For Stahl Parent B.V. and affiliated companies internal use only. Stahl Parent B.V. reserves the right to amend, update or withdraw its corporate policies
without prior notice. Version: October 2023
Page 4

Process diagram
The Whistleblower process (summary).
Suspicious behavior noticed by a Stahl Employee or other Affected
Party?
Whistleblower can consult first or file a report with the Compliance
Committee, an external local authorized agency or the Chairman of theBoard.

Consult:- Confidant- Member Compliance Committee- an Advisor

After consent of the Whistleblower
File substantiated report with a local
authorized agency. Local rules apply.

File or forward the substantiated report with/to
the Compliance Committee.

Compliance Committee confirms within 7 days
the receipt of the Report to the Whistleblower,
reviews the Report and decides on follow-up
steps.

In case of no investigation, the Compliance
Committee informs the Whistleblower within two
weeks after the receipt of the Report.

In case an investigation takes place, the Compliance Committee:-

Will notify the Whistleblower immediately that an
investigation takes place and by whom.
Inform the persons who are the subject of that Report,
unless this would hinder the investigation.
Informs the Whistleblower about its position/next steps
within 12 weeks after receiving the Report, or provide
grounds in case the term will be > 12 weeks.
Engage an External agency if necessary and if so, will
inform the Whistleblower about such notification.

The Whistleblower may escalate the handling of theReport to the Chairman of the Board, if he or she suspects
irregularities in the way of handling of the Report by theCompliance Committee or if the Report relates to amember of the Compliance Committee.

For Stahl Parent B.V. and affiliated companies internal use only. Stahl Parent B.V. reserves the right to amend, update or withdraw its corporate policies
without prior notice. Version: October 2023
Page 5

2.

Introduction

Stahl is determined to offer all employees a safe work place and has therefore implemented several
policies, such as an employee code of conduct and this Whistleblower policy.
The Whistleblower rules contained in this policy, are rules related to (suspected) irregularities
applicable to employees of Stahl Parent BV as well as to employees of its affiliated companies.
Stahl considers it important that Employees and/or Other affected parties can adequately and safely
report misconduct or Suspected Misconduct at Stahl (“Whistleblowing”).
Stahl Employees and Other affected parties are encouraged to report (Suspected) Misconduct or
further outlined in these rules.
If a Report does not fall under the scope of these Whistleblower policy, the Compliance Committee (orChairman) shall refer the person making the Report to the relevant manager/director.
In order to create and maintain a safe work place for all Stahl employees, the Board of Directors of
Stahl explicitly confirms that the position of Stahl Employees and/or Other affected parties who have ingood faith reported a (Suspected) Misconduct in accordance with the Whistleblower rules of Stahl shallnot be affected in any way as a result of making the report and that Stahl employees shall be protectedagainst intentionally filed false Reports.

3.

Definitions

In this policy, the following terms shall be understood to have the meanings assigned to them below:
▪
▪
▪
▪
▪
▪
▪
▪
▪
▪
▪

Advisor: a person who is subject to a duty of confidentiality by virtue of his position and whom
the Employee has consulted in confidence regarding Suspected Misconduct (e.g. a lawyer);
Board of Directors: the Board of Directors of Stahl Parent BV;
Chairman: the Chairman of the Board of Directors of Stahl Parent BV;
Chief Financial Officer: the Chief Financial Officer of Stahl;
Chief Compliance Officer: the Chief Compliance Officer of Stahl;
Compliance Committee: a committee existing of the Chief Financial Officer, the Chief
Compliance Officer and the Group Director HR handling the confidential administration of thisWhistleblowers policy;
Confidant: the person designated to act as a confidant for each Stahl location, as published at
MyStahl;Directive: Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October
2019 on the protection of persons who report breaches of Union law;
Dutch Whistleblower Protection Act: Act of 25 January 2023 amending the House ofWhistleblowers Act and some other Acts to implement the Directive;
Employee: the person who works or has worked for Stahl pursuant to a contract of employment
under civil law or a public law appointment, or the person who works or has worked for Stahlother than in an employment relationship;
MyStahl: the Stahl website for its employees, which can be found at https://mystahl.stahl.com ,see the compliance department page;For Stahl Parent B.V. and affiliated companies internal use only. Stahl Parent B.V. reserves the right to amend, update or withdraw its corporate policies
without prior notice. Version: October 2023
Page 6

▪
▪
▪
▪
▪
▪
▪
▪
▪
▪

▪
▪
▪
▪
▪
▪
▪
▪

▪

Employer: Stahl Parent BV and the subsidiaries and participating interests belonging to its groupor the board;
External Agency: the agency which the Compliance Committee considers the most suitable toinvestigate the external report of Suspected Misconduct;Investigators: the person or persons who are instructed by the Compliance Committee toinvestigate the Suspected Misconduct. An Investigator can be a member of the Compliance
Committee;
Local Whistleblowers Authority: the advisory and/or investigation centre of a local Whistleblowers
authority as meant in the applicable (local/national) legislations and regulations in the country of
establishment of the Employer;
Other Affected Party: includes among others external employees working for any serviceprovider or external partner or who worked for such party in the past and with whom Stahlmaintains contractual relationships;
Policy: The Stahl Parent BV Whistleblower policy;
Related Third Party: the third party related to the Whistleblower in a work-related context or alegal entity owned by the Whistleblower, for which entity the Whistleblower is employed or withwhich the Whistleblower is otherwise work-related;
Report: the report of Suspected Misconduct pursuant to this Policy;
Stahl: Stahl Parent B.V. and its (in)direct subsidiaries and participating interests belonging to its
group .
Suspected Misconduct: a misconduct noticed or suspected by an Employee or an Other Affected
Party that is occurring within the organisation of Employer at which he or she works or at anotherorganisation if he or she comes into contact with that organisation through his or her work, to theextent that:the suspicion is based on reasonable grounds stemming from the knowledge the Employee oran Other Affected Party has gained at the Employer or from the knowledge he or she has gained
from his or her work at another company or another organisation; andthere is a violation or a risk of violation of Union law; orthere is an imminent or manifest danger to the public interest, such as:a (material) violation of the Code of Conduct (such as corruption, bribes, fraud, harassment)
applicable within Stahl,a violation of a statutory provision, human rights/fundamental freedoms, including a criminal
offence,a hazard to public health,a hazard to the environment,a situation in which the proper operation of the organisation is jeopardised as a result of improper
conduct or negligent acts or omissions, such as an intentional provision of incorrect information
to public bodies, or an intentional suppression, destruction or manipulation of information
regarding those facts.
Whistleblower: the Employee or Other Affected Party who reports or publicly discloses
Suspected Misconduct pursuant to this Policy.

For Stahl Parent B.V. and affiliated companies internal use only. Stahl Parent B.V. reserves the right to amend, update or withdraw its corporate policies
without prior notice. Version: October 2023
Page 7

4.

Information, advice and support for
the Employee and the Other AffectedParty

In a case of Suspected Misconduct, an Employee or a Other Affected Party can in confidence consult:▪ the Confidant, as an advisor, as published at MyStahl;▪ the members of the Compliance Committee, in person or via whistleblower@stahl.com 1 ;▪ the Local Whistleblowers Authority for information, advice and support;▪ an Advisor.

5.

▪
▪
▪
▪
▪

▪

▪

1
2

Internal
reporting,recording,forwarding and confirming receipt of aninternal Report
An Employee or an Other Affected Party who is confronted with Suspected Misconduct within
the Employer's organisation can report that suspicion to:
any supervisor whose job title outranks the Employee's own title in the organisational hierarchy;
the Confidant;
the members of the Compliance Committee, in person or via whistleblower@stahl.com2; any of
the Compliance Committee members directly.
The channels provided for shall enable reporting in writing or orally, or both. Oral reporting shallbe possible by telephone or through other voice messaging systems, and, upon request by the
Employee or an Other Affected Party, by means of a physical meeting within a reasonable
timeframe as prescribed by local law.
Where a Report is made orally, by a recorded phone line or another recorded voice messaging
system, subject to the consent of the Whistleblower, the Employer will make a recording of theconversation in a durable and retrievable form or will document the oral reporting through acomplete and accurate transcript of the conversation. The Whistleblower will be given theopportunity to check, correct and sign for approval of the Report.
The supervisor or Confidant who receives the Report will, with the Whistleblower's consent,
forward the report as soon as possible to the Compliance Committee for the handling of theReport as described below. Should the complaint relate to one of the persons of the Compliance
Committee, it will only be forwarded to the person(s)/department(s) not involved.

This e-mail is read by the Chief Finance Officer, the Group Director HR and the Chief Compliance Officer.
This e-mail is read by the Chief Finance Officer, the Group Director HR and the Chief Compliance Officer

For Stahl Parent B.V. and affiliated companies internal use only. Stahl Parent B.V. reserves the right to amend, update or withdraw its corporate policies
without prior notice. Version: October 2023
Page 8

▪

▪

▪

▪

▪

▪
▪

▪
▪

6.
▪

In case a member of the Compliance Committee receives the Report, this member will share it
as soon as possible with the other members of the Compliance Committee or to such othermembers of the Compliance Committee who are not involved in the report, as the case may be.
The Employer keeps records of every Report received, in compliance with the confidentiality
clause provided for in Clause 11. The records shall be stored for no longer than is necessary andproportionate in order to comply with the requirements imposed by law.
The Compliance Committee will acknowledge the receipt of the Report preferably immediately,
but no later than 7 days after the Report is received by the supervisor, the Confidant or (a memberof) the Compliance Committee, to the Whistleblower. The confirmation of receipt must at least
include a concise description of the Report, the date on which the report was received, and a
copy of the Report. The acknowledgement of receipt does not mean that the Report isadmissible/will be investigated.
Stahl encourages every Employee and Other Affected Party to proactively come forward with
their concerns. To do a proper investigation of the situation, a good report is needed, as it isdifficult to investigate anonymous Whistleblower Reports. Such Report will only be investigatedin case a legal obligation or a compelling reason requires to do so, like for example, in the eventthat the Suspected Misconduct appears to be of a particularly disturbing nature, and if the details
and documents provided by the anonymous Whistleblower are sufficiently well-founded to permit
an investigation. The anonymous Whistleblower can be asked to provide an anonymous email
address or a post office box address in order to be able to continue dialoguing with suchanonymous Whistleblower.
The Employee or an Other Affected Party may escalate the handling of the Report to the
Chairman, if he or she suspects irregularities in the way of handling of the Report by theCompliance Committee or the Report is related to a member of the Compliance Committee.
The Chairman and the investigation team members will apply the same principles and rules as
described in this Policy with respect to such escalation.
The Whistleblower can make an immediate external Report of Suspected Misconduct or publicly
disclose the Suspected Misconduct in the public domain pursuant to the conditions as set forthin Clause 9 of this Policy.
A Report will not affect or diminish the statutory obligation to report a criminal offence to theauthorities.
An Employee who intentionally files a false Report will be subject to disciplinary measures as
described in the Stahl disciplinary action policy.

Processing the internal report
The Compliance Committee will immediately institute an investigation of the Suspected
Misconduct reported, unless:o the suspicion is not based on reasonable grounds; oroit is clear from the outset that the information reported has nothing to do with Suspected
Misconduct; oro the Suspected Misconduct has already been reported and investigated; or

For Stahl Parent B.V. and affiliated companies internal use only. Stahl Parent B.V. reserves the right to amend, update or withdraw its corporate policies
without prior notice. Version: October 2023
Page 9is related to facts that have already been addressed.
If the Compliance Committee opts not to begin an investigation, it will notify the Whistleblower ofthat fact in writing within two weeks of the internal Report. This notification must indicate why no
investigation will be instituted.
The Compliance Committee will assess whether an External Agency must be notified of aninternal Report of Suspected Misconduct. If it notifies an External Agency, it will send theWhistleblower a copy of the notification, unless such would work to the detriment of investigativeor enforcement-related interests.
If the Compliance Committee has notified an External Agency of the internal Report, it may join
its investigation with that which the External Agency may cause to be conducted.
The Compliance Committee will charge independent and unbiased parties to conduct theinvestigation.
The Compliance Committee will notify the Whistleblower, immediately and in writing, that an
investigation has been instituted and by whom it will be conducted.
The Compliance Committee will notify the persons who are the subject of that Report, unlesssuch would work to the detriment of investigative- or enforcement-related interests.
o

▪

▪

▪
▪
▪
▪

7. Conducting the internal investigation
▪
▪
▪
▪
▪
▪
▪
▪
▪

▪

The Investigators will allow the Whistleblower the opportunity to be heard. The Investigators will
provide feedback to the Whistleblower.
The Investigators will allow the person who is the subject of the Report the opportunity to beheard, unless this would work to the detriment of investigative- or enforcement-related interests.
If necessary, a third party counsel will be involved by the Investigators to assist with theinvestigation.
The Investigators may also hear statements from others. The Investigators will prepare a reportand submit this report to the person giving the statement for his approval and signature.
The Investigators may request the Whistleblower to submit documents within the Whistleblower's
organisation which they consider reasonably necessary to conduct the investigation.
The Investigators will prepare a draft investigation report and afford the Whistleblower theopportunity to provide feedback on the conclusions made.
The Investigators will then finalise the investigation report. They will provide the Whistleblower
with the conclusions, unless there are compelling objections against this.
The parties involved will be obliged to observe confidentiality with regard to the (draft)report/conclusions.
Within twelve weeks of the Report, the Compliance Committee will notify the Whistleblower inwriting of its position on the Suspected Misconduct reported and indicate the steps to which theReport has led.
If it is clear that this position cannot be communicated within twelve weeks, the Compliance
Committee will notify the Whistleblower of that fact in writing. That notification will indicate theterm within which the Whistleblower can expect to be informed of that position. If the total term
will exceed twelve weeks, grounds must be provided for this.

For Stahl Parent B.V. and affiliated companies internal use only. Stahl Parent B.V. reserves the right to amend, update or withdraw its corporate policies
without prior notice. Version: October 2023
Page 10

▪

▪

8.
▪
▪

9.
▪

▪

After the investigation is completed, the Compliance Committee will assess whether an External
Agency must be notified of the internal Report, the investigation report, and/or the Compliance
Committee’s position. If the Compliance Committee notifies an External Agency, it will send theWhistleblower a copy of the notification, unless such would work to the detriment of investigativeor enforcement-related interests.
The person who is the subject of the Report of the investigation will be notified in the same way
as the Whistleblower, unless this would work to the detriment of investigative- or enforcementrelated interests.

Information about outcome
The Whistleblower is encouraged to substantiate its report in order to allow the Compliance
Committee to adequately assess the facts and, if applicable, conduct the internal investigation.
The Compliance Committee informs the Whistleblower about the outcome of the report and if
applicable about the outcome of the investigation as described in Clause 7 of this Policy.

External report and public disclosure
An Employee or Other Affected Party is also authorised to:o make an external Report of the Suspected Misconduct to a Local Whistleblowers
Authority's investigation centre or another authorised agency as prescriped by local law;oro publicly disclose the Suspected Misconduct in the public domain if and to the extent that
the Employee or Other Affected Party:▪ first reported internally and externally, or directly externally in accordance with
the Directive, but no appropriate action was taken in response to the report
within the timeframe referred to in point (f) of Article 9(1) or point (d) of Article
11(2) of the Directive; or▪ has substantiated- or duly justified reasons to believe that:▪ the breach may constitute an imminent or manifest danger to the public
interest, such as where there is an emergency situation or a risk ofirreversible damage; or▪ in the case of external reporting, there is a risk of retaliation or there isa low prospect of the breach being effectively addressed, due to theparticular circumstances of the case, such as those where evidence
may be concealed or destroyed or where an authority may be incollusion with the perpetrator of the breach or involved in the breach.
This Article shall not apply to cases where an Employee or Other Affected Party directly discloses
information to the press pursuant to specific applicable local laws establishing a system ofprotection relating to freedom of expression and information. Protection applies provided that theconditions as set forth in Article 10 applies in full.

For Stahl Parent B.V. and affiliated companies internal use only. Stahl Parent B.V. reserves the right to amend, update or withdraw its corporate policies
without prior notice. Version: October 2023
Page 11

10. Protection
10.1 Protection of the Whistleblower
▪

▪
▪
▪
▪
▪
▪
▪
▪
▪
▪
▪
▪
▪
▪
▪
▪
▪
▪

▪

The Employee, Other Affected Party and/or a Related Third Party who reports or discloses
Suspected Misconduct will not be subjected to unjustified detriment as a result of that Report ordisclosure either during or after the processing of this report by the Employer, anotherorganisation, or an External Agency, if the Employee, Other Affected Party and/or a Related
Third Party believes on reasonable grounds that the information on the Suspected Misconduct
was true at the time of reporting and that such information fell within the scope of this Policy,
The term 'unjustified detriment' will in any case encompass the taking of, but also the threat of
and/or the attempt to a discriminatory measure, such as, but not limited to:suspension, lay-off, dismissal or equivalent measures;
demotion or withholding of promotion;transfer of duties, change of location of place of work, reduction in wages, change in working
hours;
withholding of training;a negative performance assessment or employment reference;
imposition or administering of any disciplinary measure, reprimand or other penalty, including afinancial penalty;
coercion, intimidation, harassment or ostracism;discrimination, disadvantageous or unfair treatment;
failure to convert a temporary employment contract into a permanent one, where the worker had
legitimate expectations that he or she would be offered permanent employment;
failure to renew, or early termination of, a temporary employment contract;
harm, including to the person's reputation, particularly in social media, or financial loss, including
loss of business and loss of income;blacklisting on the basis of a sector or industry-wide informal or formal agreement, which may
entail that theperson will not, in the future, find employment in the sector or industry;
early termination or cancellation of a contract for goods or services;
cancellation of a licence or permit;
psychiatric or medical referrals.
The Employer will ensure that the Whistleblower is not subjected to other unjustified detriment atwork as a consequence of the Report or public disclosure. If the Whistleblower is subject tounjustified detriment, it shall be presumed that the detriment was made in retaliation for theReport or the public disclosure. In such cases, it shall be for the Employer who has taken the
detrimental measure to prove that that measure was based on duly justified grounds.
If, after a Report or disclosure is made, the Employer takes a measure with unjustified detriment
for the Whistleblower, the Employer must provide the reasons why it considered this necessary
and provide ground demonstrating that such measure is unrelated to the good-faith reporting or
disclosure of the Suspected Misconduct.

For Stahl Parent B.V. and affiliated companies internal use only. Stahl Parent B.V. reserves the right to amend, update or withdraw its corporate policies
without prior notice. Version: October 2023
Page 12

▪
▪

▪

▪

The Employer will call Employees who discriminate against the Whistleblower to account for theiractions, and may issue a warning or impose disciplinary measures on such employees.
Without prejudice to Article 3 of the Directive, the Whisleblower or a Related Third Party shall not
be considered to have breached any restriction on disclosure of information and shall not incur
liability of any kind in respect of such a Report or public disclosure provided that the
Whistleblower had reasonable grounds to believe that the reporting or public disclosure of suchinformation was necessary for revealing a breach pursuant to the Union law.
The Whistleblower or a Related Third Party shall not incur liability in respect of the acquisition ofor access to the information which is reported or publicly disclosed, provided that such acquisitionor access did not constitute a self-standing criminal offence. In the event of the acquisition oraccess constituting a self-standing criminal offence, criminal liability shall continue to be
governed by applicable national law.
The burden of proof that the Whistleblower or the Related Third Party does not meet theconditions referred to in the previous two paragraphs shall lie with the person or entity who has
held the Whistleblower liable.

10.2 Counteracting negative measures for the Whistleblower▪

▪

If the Whistleblower believes that he or she is actually a subject of unjustified detriment, he or
she can discuss this with the Confidant, including the measures to counteract such unjustified
detriment. The Confidant will prepare a report of this discussion and will send it, after it isapproved by the Whistleblower, to the Compliance Committee.
The Compliance Committee will ensure that the necessary measures are taken to counteract theunjustified detriment.

10.3 Protection of other parties involved from negative measures▪

The Employer will not take measures with unjustified detriment towards:
o The Advisor employed by the Employer because of his acting as an Advisor to theWhistleblower;
o The Confidant because of his performance of the duties described in this Policy;o The Investigators employed by the Employer because of their performance of the duties
described in this policy;o An Employee or Other Affected Party who is heard by, in accordance with the provisionsof this policy provides documents to, or otherwise cooperates with the Investigators
when making a statement in good faith.

10.4 Internal and external investigation of negative measures for the Whistleblower▪

▪

A Whistleblower who believes he or she is being subject of unjustified detriment as the result ofreporting Suspected Misconduct can request the Compliance Committee to investigate themanner in which he or she is being treated within the organisation.
The persons referred to in 10.2 and 10.3 can also request the Compliance Committee toinvestigate the manner in which they are being treated within the organisation.

For Stahl Parent B.V. and affiliated companies internal use only. Stahl Parent B.V. reserves the right to amend, update or withdraw its corporate policies
without prior notice. Version: October 2023
Page 13

▪

The Whistleblower can also request a Local Whistleblowers Authority's investigation centre to
institute an investigation into the Employer’s conduct towards the Whistleblower in connection
with the reporting of Suspected Misconduct.

11. Confidentiality
▪

▪

▪

▪
▪

▪
▪

The Compliance Committee will ensure that the information about the Report is stored in such a
way that it is physically and digitally accessible only by the persons involved in processing theReport.
The persons who are involved in processing the Report will not disclose the Whistleblower's
identity without the latter's express written consent and will treat all information regarding theReport as confidential.
In the event that any legal provision requires the communication of the competent authority or in
the context of legal proceedings to disclose the identity of the Whistleblower, the Whistleblower
shall be informed thereof in advance, unless this information might jeopardise the related
investigation or judicial proceedings.
At the time of the notification referred to above, a Whistleblower will receive a written explanationof the reasons for the disclosure of the data concerning his/her identity.
If Suspected Misconduct is reported via the Confidant and the Whistleblower has not consented
to the disclosure of his identity, all correspondence regarding the Report will be addressed to the
Confidant. The Confidant will immediately forward such correspondence to the Whistleblower.
The persons who are involved in processing the report will not disclose the Advisor's identity
without the express written consent of both the Whistleblower and the Advisor.
Stahl Parent BV privacy policies apply. It is noted that in no event the application of the privacy
policies (such as access rights) may result in disclosing the identity of the Whistleblower to theperson indicated in the whistleblower Report.

12. Reporting and evaluation
▪
▪

▪
▪

▪
▪

The Compliance Committee will prepare a semi-annual report concerning the implementation ofthis Policy. This report will in any case contain:
information about the number of Reports and an indication of the nature of the Reports (incl.
whether Reports were made anonymous or not), the results of the investigations, and thepositions of the Employer;
general information about any experiences of counteracting discrimination against the
Whistleblower;
information about the number of requests for investigation of discrimination connected to thereporting of Suspected Misconduct and an indication of the results of the investigations and thepositions of the Employer.
identification of trends (if any)
repeated whistleblower topics (if any)

For Stahl Parent B.V. and affiliated companies internal use only. Stahl Parent B.V. reserves the right to amend, update or withdraw its corporate policies
without prior notice. Version: October 2023
Page 14▪

▪

The Compliance Committee will discuss the report with the audit committee of Stahl Parent BV
at least twice a year, which should treat such report as confidential. The Compliance Committee
will immediately send a report to the Audit Committee in case of a major issue.
Any information with respect to the investigations shall not be kept longer by the Compliance
Committee than strictly necessary and legally permitted in the (electronic) files of the people
involved.

This policy was approved by the Audit Committee and took effect on October 23, 2023.

For Stahl Parent B.V. and affiliated companies internal use only. Stahl Parent B.V. reserves the right to amend, update or withdraw its corporate policies
without prior notice. Version: October 2023
Page 15