It is o.k. to speak up if you feel something could harm the company, a co-worker or yourself. If such a situation occurs, it is vital that you take action. Never look away, even if you’re unsure.

There are various ways and levels to raise your concern. Choose your way, depending on the type of concern you have and how comfortable you feel raising it.

• Preferably, give feedback to the person involved. Minor issues are almost always best dealt with this way.
• Do you believe the situation can’t be resolved this way or that you are dealing with a more severe issue? Go to your manager or the next manager higher up. You can also talk to your HR Manager or the Ethics & Compliance Officer*. They are there to listen and take appropriate action.
  *Your local situation may also offer other options such as a confidential counsellor. In addition to making an internal report, local law may offer the option to report to specialized local authorities.
• Do you suspect a potential violation of our safe, fair and trusted work environment, policies or the law? Does it feel uncomfortable taking any of the actions above? If this is the case, then you should use the ERIKS Speak Up Service.

ERIKS Speak Up Service is there for you. This is the place to raise concerns about a potential violation of:

• any ERIKS policies and guidelines;
• any applicable code of conduct;
• local laws, rules or regulations.

Some examples are bribery, harassment, fraud or alcohol abuse. Know that we welcome all concerns raised in good faith, even if the report turns out to be unfounded or resolved in a different manner. We trust you to use this service fairly and responsibly.

Anyone who feels or suspects that something isn’t right can raise a concern using the Speak Up Service. This includes employees, contractors, former employees, business partners and customers.

We value your opinion. Therefore ERIKS offers various channels for concerns, not suitable for the Speak Up Service.

• If you disagree with management decisions, such as promotions, reorganisations and salary negotiations → Contact your manager or HR department. If these decisions violate our policies or the law use the Speak Up Service.
• In case of an immediate threat → Please contact your public emergency services, such as the ambulance or police.

You can reach the Speak Up Service in two ways:

• Call the Speak Up phone line
  • When you call the Speak Up phone line, you can select your language and speak to the operator (via an interpreter). They will listen and may ask additional questions.
  • Click the “Share a concern by phone” button on the ERIKS Speak Up home page to find the phone number for your country. The lines are toll-free and operated 24/7 throughout the year.
• Submit a report on the Speak Up website
  • Report your concern via the “Share a concern online” button on the ERIKS Speak Up home page. You will get several questions before you can submit the form.

Please share your concern through the Speak Up website. Mention in the report that the telephone number did not work or your location wasn't listed, so we can fix it.

All calls are answered by independent external operators from NAVEX, the company who provides the Speak Up phone line and website, on behalf of ERIKS. They will send a summary of your phone call to the ERIKS Speak Up team.

All reports submitted online are first checked by NAVEX and then sent to the ERIKS Speak Up team.

When submitting your report, give us as much information as possible. Be as factual as possible. It is a great help if you can answer these questions:

• What happened?
• Where did it happen?
• When did it happen?
• Is this an ongoing issue?
• Who is involved?
• Were there witnesses?
• What evidence is available?

We appreciate it when you give your name and contact details. This makes the investigation easier. If you’re uncomfortable identifying yourself, you can report your concern anonymously. Anonymous reports are treated just as seriously. However, sometimes anonymous reports are harder to investigate because of this anonymity. For instance if we don’t have enough information and we need to contact you for further information.

We keep you safe in various ways:

Anonymity

We guarantee that your report is treated anonymously:

• NAVEX makes sure your phone call is non traceable.
• NAVEX guarantees that no IP address information directs back to you.
• Speak Up reports from your computer come through a secure Internet port and do not trace or show user names.
• NAVEX will not use information for any purpose other than providing it to ERIKS for this purpose.

Confidentiality

ERIKS only shares information with those people who have a need-to-know.

Investigations are focused on facts. The ERIKS Speak Up team checks 1. whether an allegation is correct and 2. whether our safe, fair and trusted work environment, the law or regulations have been violated. We conduct our investigations in an independent, fair and unbiased manner. We respect all parties involved.

Non-retaliation

If anyone tries to hurt or harm you after sharing a concern, you are dealing with retaliation. This can be very subtle, and even unintentional.

We have a non-retaliation policy. Therefore anyone raising a concern must be treated as if no report was filed. It doesn’t matter if a concern later turns out to be unfounded, mistaken or misguided.

If you believe you have faced retaliation of any kind, please report it directly to management or through Speak Up. Fill in a new form or add a follow-up message to the already existing report.

Unfortunately, we sometimes receive a report that is not only false, but deliberately false. Know that we respond strictly on Speak Up abuse.

If you have raised a concern using the Speak Up Service, you can expect the following next steps:

1. Processing and transferring: Your report will be processed independently by a member of the NAVEX team and securely sent to the ERIKS Speak Up team.
2. Initial review: The ERIKS Speak Up team is completely independent and knows how to assess your report.
3. Assigning a case handler: The ERIKS Speak Up team assigns your report to the best person to deal with it. The Ethics & Compliance department will monitor to make sure that it is dealt with in a fair and timely manner.
4. Investigation and actions: The case handler investigates your report and does its best to understand all the facts of what happened. If necessary, we will take appropriate actions, such as giving advice, improving a situation, increasing safety measures or giving an official warning.
5. Feedback to you as the reporter: We will give you regular updates during the investigation. And let you know once the investigation has been finalised. Call the phone line or log in to the Speak Up website with your Report Key to stay informed.

Your company will investigate your concerns with an independent case handler. This might be someone within the organisation, or an independent person or agency outside the company. The case will be handled at least one management level up from where the concern reported exists.

After you complete your Speak Up report by phone or online, we request you monitor the progress as well. We will do our best to keep you informed, however we cannot always provide details due to privacy regulations.

You will receive an unique code called a Report Key. You will also be asked to create a password. You can use this Report Key and password to return to the Speak Up phone line or website to check the status of your report or provide additional information.

You will receive a Report Key after submitting your report and will be asked to create a password.

If you lose or forget your Report Key or password: please file a new report, and mention that it is related to a report you previously filed. As we do not keep a record of passwords and report keys to protect everyone’s privacy.

ERIKS has contracted NAVEX. This is an international operating company that provides secure, confidential telephone and web-based systems.

NAVEX makes it possible to easily report violations of our safe, fair and trusted work environment, the law or regulations.

The Speak Up phone line and reporting website of NAVEX are available 24 hours a day, seven days a week. It provides interpretation services for telephone and web reporting in different languages.

The responsibilities of NAVEX are:

• Provide telephone and web-based options through which people can report potential violations of our safe, fair and trusted work environment, the law or regulations.
• Protect the identity of reporters who wish to remain anonymous.
• Provide interpretation services for reporters wishing to report in a different language than English.
• Passing on all reported concerns to the ERIKS Speak Up team for investigation and further handling.
• Allow the ERIKS Speak Up team to communicate with a reporter, who wishes to remain anonymous, by acting as an intermediary.

It is NOT NAVEX’s role to take action to address the concern. Handling a concern is the responsibility of the ERIKS Speak Up team.

First and foremost, Speak Up is part of our culture. With Speak Up we create a safe, fair and trusted work environment. Together. It helps us address any potential issues quickly. As a manager, you have a vital role in stimulating a Speak Up culture in your team.

If you want to know how, these tips can lead you the way:

Talk about it

• Be available, talk with employees regularly so that they are used to it
• Speak in terms of “we”
• Give honest feedback

Care and act

• Listen (with an open mind)
• Act fair and reliable
• Explain your decisions
• Ask people for their ideas and opinions

Lead by example

• Address unrest, uncomfortable or inappropriate situations. Otherwise they will only get worse.
• Reflect on your own behaviour and how your language or behaviour might affect others.
• Take responsibility, be open about mistakes you make.

If an employee shares a concern, it has probably already been on his/her mind for a longer time. Encourage and praise this step. Speak Up is as much about speaking as it is about listening.

Let the following tips guide you:

• Take your time, or plan a meeting if necessary.
• Listen carefully and show that you do so.
• Summarise to verify if you understood the concern.
• Make sure you have all the information you need and use below checklist to do so.
• Thank the employee for sharing.
• Explain what your next steps will be and when you will be in contact again.
• Treat your conversation with respect and keep it confident.

Checklist: Make sure you get all the relevant information

• What happened?
• Where did it happen?
• When did it happen?
• Is this an ongoing issue?
• Who is involved?
• Were there witnesses?
• What evidence is available?

Also check the Guidance for managers to see which steps to take.

If someone shares a concern, show you are taking action and treat it confidentially and with respect. Explain which information you will share and with whom. Make sure the employee understands the possible implications.

Confidentiality has to be considered at every stage. Make sure you inform only those people who have a need-to-know. Keep the name and identity of the person who shared the concern confidential where possible. Only share names if this is an absolutely necessity for the follow-up actions.

If you have a full understanding of the concern shared, you can assess if you can deal with the report yourself. If you are in doubt, ask for support.

Checklist: Questions to consider escalation

• Are senior officials of the company involved?
• Is it related to fraud or accounting matters?
• Is the reputation, integrity, operations or finance of the company at serious risk?
• Is the fair, safe and trusted work environment at serious risk?
• Are normal procedures or controls deliberately circumvented?

If you can answer ‘yes’ to one or more of these questions, we advise you to ask for support. For example, you can turn to HR, Ethics & Compliance, Legal or Senior Management.

If you feel confident that no escalation is needed, you can deal with the issue yourself.

1. Use open communications on all subjects, but do consider confidentiality.
   
   This means that you are transparent about who you talk to and about what. About which steps you will take and why. If you want to improve, change or address something it always starts with communication. This goes for any subject, big or small. This is the basis of your actions.

2. Make sure you inform the employee about the steps you are planning to take, but keep in mind the privacy of those involved.
   
   When you have taken action, inform the employee of the outcome. You show you’ve taken action and you keep in touch. If you consider disciplinary measures, please involve HR.

3. If everything is dealt with, inform the employee about this in a confidential conversation.
   
   Thank him/her again for sharing. Express you hope that the provided solution is satisfactory. Or clearly explain the outcome. Evaluate the process with all parties involved. In this way we keep on improving our Speak Up culture and procedures. Be sure that the issue doesn’t occur again, that no retaliation* takes place, and that the employee gets the care he/she needs. This monitoring keeps everyone safe and healthy.
   
   * You are dealing with retaliation if anyone treats the employee less favourable because of sharing a concern.

Also check the Guidance for managers to see which steps to take.

If you have considered the questions as described in Question 4 and you need support from your colleagues, consider to inform the employee first.

Choose, depending on the nature of the concern, the most suitable go-to person. Go with issues related to:

• HR subjects (such as mediation, coaching/training, disciplinary measures) > HR
• Violations of law or policies (such as bribery, corruption, contractual issues) > Ethics & Compliance and/or Legal
• Accounting matters or misuse of funds (such as fraud, embezzlement, theft) > Internal Audit
• Other subjects > Senior Management

If you escalate the concern, consult with this department about the next steps to take. Divide the tasks and inform the employee about this.

If you can close the report, inform the employee about this in a confidential conversation. Thank him/her again for sharing. Express you hope that the provided solution is satisfactory. Or clearly explain the expected outcome. Ask the employee if after care is needed.

To make sure everyone can Speak Up safely, we have a non-retaliation policy. The best prevention is to keep the identity of the reporter confidential. Otherwise, you might see retaliation.

If anyone treats the employee less favourable because of sharing a concern, you are dealing with retaliation. This can be very subtle, and even unintentional. This checklist can help you to identify retaliation:

• Is the employee excluded or left out?
• Is the employee reassigned to a less favourable shift?
• Is the employee not considered for a promotion or project?
• Are there salary adjustments, e.g. is a bonus denied?
• Is the employee subject of jokes or harassment?
• Is the employee dismissed?

Anyone raising a concern must be treated as if no report was filed. As a manager, you have a vital role in preventing retaliation by taking confidentiality very seriously.

If you believe you or your employee have faced retaliation of any kind, please deal with it in a fair and respectful way. Talk to the person(s) that engage in retaliation. Explain that it is important to talk about concerns, as it helps to maintain a safe, fair and trusted work environment.

If you need help, do not struggle yourself but ask for help. Your own manager, HR or Ethics & Compliance Officers are there for guidance and/or support. If you need expert advice, you can ask any applicable expert function, e.g. the Legal department, Internal Audit, IT or Loss Prevention. If you have no one to turn to, you can share your concern using the Speak Up Service yourself.