The hotline, including online intake or by phone, is one of our speak-up channels to raise concerns about ethical issues and potential misconduct. It is a service Astemo Group offers for current and former employees, officers, customers, suppliers and other stakeholders.

NAVEX, an independent third party, operates the hotline.

Astemo Group is committed to creating and maintaining an environment where anyone can raise concerns about ethical issues and potential misconduct without fear of retaliation. Like many global companies, Astemo Group provides the Astemo Group Compliance Hotline as an optional service for employees to speak up.

Discuss questions and concerns with your manager. If not, the Astemo Group Compliance Hotline provides an additional way to receive help if you feel uncomfortable asking questions or expressing concerns to management.

Use the hotline if you have concerns about ethical issues and potential misconduct. Alternatively, you could raise your concern through your management, HR or Legal. Your decision to use the hotline is voluntary.

An ethical issue includes any actual or suspected breach of Astemo Group’s Code of Conduct and any other improper or illegal conduct. It also includes any violation of the Astemo Group’s Code of Conduct by our third parties who have committed to obeying it.

The hotline does not cover employee grievances, complaints relating to job performance, or the terms and conditions of employment. These issues are not complaints that relate to potential malpractice or material misconduct.

The table below shows examples of ethical issues.

We all have the right to work in a positive environment. With that right comes the responsibility of acting ethically and letting the appropriate people know if someone is not acting appropriately. By working together, we can maintain a healthy and productive environment. Corporate misconduct can threaten the livelihood of an entire company.

Yes. Astemo Group requires employees to raise concerns as soon as they become aware of potential misconduct. Raising a concern can minimize the possible negative effect on Astemo Group and our people regarding financial, legal or reputational risks and health and safety threats.

If you are unsure whether the concern is justified and you feel comfortable contacting your management, HR or Legal, please do so. Contact the hotline if you do not feel comfortable raising the concern with your manager or management, and HR or Legal confirms that your concern could be an ethical issue or potential misconduct.

Only a select number of respective Astemo Group compliance team members in charge of the investigation have access to reports. The EthicsPoint system and distribution protocols are designed so any individuals named in the report are not notified about or granted access to reports in which they have been named.

No. Astemo Group provides the hotline for your use and protection. Retaliation against anyone who raises an ethical concern in good faith is unacceptable. If a reporter informs Astemo Group about retaliation, Astemo Group takes this seriously and investigates. Astemo Group will discipline anyone who engages in retaliation.

EthicsPoint does not generate or maintain any internal connection logs with IP addresses, so no information linking your computer to Ethics Point is available. EthicsPoint is contractually committed to not pursuing a reporter’s identity. If you feel uncomfortable making a report on your work PC, use a PC outside our work environment (such as one located at a friend’s house or a public library or internet café) through the EthicsPoint secure website.

Yes. Your concern or question is entered directly onto the EthicsPoint server over a secured connection. EthicsPoint’s servers do not connect to Astemo Group’s information technology systems. Only a select number of global departments within your respective Astemo Group responsible for managing and following up on your report have access to this information.

You may remain anonymous in all countries except those that prohibit anonymous reporting. Although it may be easier in many cases to address your issue by identifying yourself, you are not required to do so. If you remain anonymous, EthicsPoint or Astemo Group will not make an effort to identify you.

Yes. When you report a concern via the hotline, the system will provide a report key and prompt you to select a password.

Store the report key and password in a safe place. With this key, the investigators can maintain communication with you. They, or you, could ask for further information and provide feedback to you where necessary.

The hotline has two methods of intake. With EthicsPoint, you can raise a concern in confidence by web intake or by telephone. Choose one channel, do not duplicate the report by using both channels.

The first channel is the intake portal. The intake form consists of questions to identify the relevant details of your concern or question and is to understand:

• what happened,
• who are involved,
• where and when did it happen and;
• how did it happen.

The web intake portal is available 24 hours a day, seven days a week, every day of the year. You may access it from any computer that has an internet connection.

If you have documents, photos, recordings or videos, you could upload to the web intake portal.

No. If you close your internet browser while completing the form, the EthicsPoint web intake portal will not save the information you have entered, so choose a time and place to use the system to complete the form.

The second channel is a toll-free telephone number by country. This service is available 24 hours a day, seven days a week, every day of the year. A professionally trained EthicsPoint operator will guide you through a series of questions to identify the relevant details of your concern or question to understand:

• what happened,
• who are involved,
• where and when did it happen and;
• how did it happen.

The operator will also ask you to provide supporting documentation, if available. If you have documents, photos, recordings or videos, you could upload them to EthicsPoint after you complete the report, and the system generates the encryption key.

At the conclusion of the call, the operator will summarize the information you have submitted and make any necessary changes to ensure that you are satisfied with the accuracy of your question or concern.

The hotline offers toll-free numbers in countries where Astemo Group operates and is available in more than 50 languages. Multilingual operators are available so callers can ask questions or raise concerns in their native or preferred language.

Provide information in as much detail as possible. Details should include the who, what, when, where, why, and how concerning the allegation(s) raised. If possible, you can attach evidence such as documentation or emails that help substantiate your claim(s). Reports that do not reasonably satisfy conditions of completeness may not be reviewed or investigated further.

Select a nearby country and include the actual location in the case description.

When you ask a question, the system will direct it to the respective Astemo Group compliance team, who will respond to you through the hotline.

Whether made by web intake or telephone, all concerns are reviewed promptly by a professionally trained EthicsPoint intake specialist. The EthicsPoint intake specialist will send a report to the designated global department within your respective Astemo Group Company responsible for managing and following up on your report.

The appointed team members will start the investigation if you provide sufficient details.

If necessary, Astemo Group will take appropriate remedial action while the investigation is ongoing. Those responsible for following up on your matter are trained professionals who handle the issue with discretion.

All reports, through web intake or telephone, are entered into a database for recordkeeping and case management. Only representatives within your respective Astemo Group Company have access to this information.

Yes. You receive a confirmation that your report has been received, usually within one to seven business days. After the conclusion of the investigation, you will receive a message notifying you that the investigation has been closed. The email will indicate that all appropriate actions, if or where necessary, have been taken. You do not receive details about the investigation for confidentiality reasons.

When you raise a concern, either using the web or by telephone, the system will provide a report key and prompt you to select a password.

With the report key and password, you can return to the EthicsPoint system by Internet or telephone and access the original report. At that point, you can add more details.

The system will provide a report key and prompt you to select a password. Record the report key and password and keep them in a safe place. Use your report key and password to re-contact EthicsPoint to check on the status of your case, provide more information, or answer follow-up questions from those investigating the matter.

When given your report key and password, you can follow up with EthicsPoint by telephone or web, even if you report anonymously. If an investigator wants to contact you regarding your concern, the investigator can leave you a message or ask you a question through EthicsPoint.

Because of the confidentiality level maintained for reports, the process requires you to file a new report if you lose your report key or password. You can mention in the latest report that this matter relates to another report you filed earlier.