Reporting of concerns

Whistleblowing

Reporting of concerns (whistleblowing)

We kindly ask you to notify us if you experience anything that you believe is not in accordance with laws, regulations or UBConnect’s values and code of conduct.

What is reporting of concerns (whistleblowing)?

Reporting of concerns (whistleblowing) is to report possible illegal, or suspected critical issues. Critical issues are violations of legal rules, violations of internal rules or violations of ethical norms.

Reporting of concerns is positive

Reporting of concerns for both the company and community is very important and positive, because criticism can be rectified. People who are willing to report their concerns are an important resource for UBConnect.

Right and duty to report concerns

Individuals are encouraged to notify and report critical issues, as it contributes to the positive development of UBConnect, but is normally not an obligation.

Employees are obliged to notify about criminal issues and about conditions in which life and health are in danger.

Follow-up of the reported concerns

The management must decide how to fix the concerns that have been reported. The whistleblower shall have a feedback within one week.

If the concern proves to be based on a misunderstanding, the whistleblower should receive a proper explanation.

The management has also a responsibility to take care of people who have been subjected to baseless criticism.

The person reporting concerns will not be punished

A whistleblower who experiences this must notify the CEO or the chairman of the board who will immediately handle the case.

Who shall you report your concerns?

Both the case and the situation will determine how it is best to report your concerns. Here is the starting point for what we think is best at UBConnect:

• All cases can be reported to the immediate superior.

• Personnel cases can be reported to safety representatives or HR.

• Environmental issues or poor working environment can be reported to the head of the Working Environment Committee (AMU).

• Violation of tax or corruption rules can be reported to the CFO.

If the whistleblower does not receive a response or feedback, the whistleblower is encouraged to inform the CEO or Chairman of UBConnect.

External reporting of concerns:

UBConnect has an agreement with PWC Norway for external report of concerns. They have a duty of confidenciality as to the whistleblower, and they agree with the whistleblower how the report will be presented to UBConnnect. The report of concerns can be made at: https://trustcom.pwc.no/ubconnect.

Anonymity and confidentiality

The report of concerns can be made anonymously, but transparency will normally ensure better litigation and a better outcome for all parties involved. The whistleblower is regardless a confidential information.