Welltec A/S and its subsidiaries and affiliates (collectively “WELLTEC”) require their directors, officers, and employees (collectively “Employees”) to maintain the highest level of integrity and ethics, complying with the letter and the spirit of all applicable laws and regulations.
This policy creates an ethical and open work environment, ensures that WELLTEC has a governance and accountability structure that supports its mission, and encourages and enables Employees to raise legitimate concerns about potential illegal or unethical acts within WELLTEC. This policy does not create an employment contract and does not modify the employment relationship between WELLTEC and any Employee, nor does it change any at-will employment status you enjoy with WELLTEC.
Reporting Responsibility: All Employees have a responsibility to report any action or suspected action that relates to issues of internal controls in the areas of finance, accounting, banking, anti-corruption and certain other categories of issues only ("Violations"). Any concern regarding an area other than outlined above must be reported to local Welltec management or HR.
Anyone reporting a Violation must act in good faith, without any malice, and have reasonable grounds for believing the information reported indicates a Violation has occurred. An Employee who makes a report does not have to prove that a Violation occurred. However, if an Employee makes a report for malicious reasons or has good reason to believe a report is false, the Employee will be subject to disciplinary action, which may include termination for cause.
No Retaliation: No Employee will suffer retaliation or other adverse employment consequence for good faith reporting or cooperation in the investigation of a Violation. Applicable law prohibits retaliation or other adverse employment consequence for good faith reporting or cooperation in the investigation of a Violation. Any Employee who retaliates against another Employee for reporting a Violation or cooperating in the investigation of a Violation is subject to disciplinary action, which may include termination for cause.
If you believe that an Employee who reported or cooperated in the investigation of a Violation is suffering retaliation or other adverse employment consequences, please contact the Vice President Legal Services, APAC & ERC.
Reporting Process: All Employees should address matters regarding a Violation to any person within WELLTEC who can properly address it. Generally, your immediate supervisor is the person best suited to address a concern.
However, if you are uncomfortable discussing it with your supervisor, or you do not believe your supervisor has dealt with it properly, you should report the issue through Welltec’s Whistleblower System.
All reporting through Welltec’s Whistleblower System can be done anonymously.
Vice President Legal Services, APAC & ERC: The Vice President Legal Services, APAC & ERC should be immediately notified of a Violation. He is responsible for promptly investigating all reported Violations and causing appropriate corrective action to be taken, if any.
The Vice President Legal Services, APAC & ERC shall report regularly to the CEO regarding any compliance activity.