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Whistleblower Policy

EU Whistleblower Directive 2019/1937 / Hextal Group N.V.

1. Purpose

Hextal is committed to the highest standards of ethical conduct, transparency, and accountability. This policy establishes a secure and confidential mechanism for employees, contractors, suppliers, and members of the public to report concerns about wrongdoing without fear of retaliation.

2. Scope

This policy covers all entities within the Hextal Group and applies to reports concerning: fraud, corruption, or bribery; violations of laws or regulations; health and safety risks; environmental damage; modern slavery or human rights abuses; discrimination or harassment; conflicts of interest; and misrepresentation of financial information.

3. How to report

Reports can be submitted through the following channels:

Independent reporting line

Operated by an external, independent provider. Available 24 hours a day, 7 days a week, in 14 languages. Reports can be made anonymously.

Phone: +31 (0) 800 022 4488 (toll-free within NL)
International: +31 10 794 2200
Written reports

Group Compliance Officer, Hextal Group N.V., Wilhelminakade 173, 3072 AP Rotterdam, the Netherlands. Envelopes marked “Confidential — Whistleblower” are opened only by the Compliance Officer.

Email
compliance@hextal.eu

Encrypted email is available upon request.

4. Protection against retaliation

Hextal strictly prohibits retaliation against any person who makes a report in good faith. Protection extends to the reporting person, their colleagues, and any person who assists with the report. Retaliation includes dismissal, demotion, harassment, discrimination, or any other adverse action. Violations of this protection will be treated as serious misconduct.

5. Investigation process

All reports are assessed within 7 days of receipt. Investigations are conducted by the Group Compliance team or an independent external investigator where appropriate. The reporting person receives feedback on the progress and outcome of the investigation within 3 months, subject to legal constraints. All investigations are documented and reported to the Audit Committee of the Supervisory Board.

6. Confidentiality

The identity of the reporting person is treated as strictly confidential and is disclosed only where legally required or with the reporting person's explicit consent. All data related to whistleblower reports is processed in accordance with the General Data Protection Regulation (GDPR) and Hextal's Privacy Policy.