whistleblower policy for third parties

June 2025

Introduction

Euro Pool Group is committed to doing business with integrity and in a sustainable way. A part of this is by creating a culture where third parties, working with Euro Pool Group, can raise concerns about a (suspected) violation of applicable laws and regulations, or other misconduct.

Scope

This policy applies to all (employees of) suppliers, service providers, contractors and subcontractors of Euro Pool Group. Euro Pool Group encourages these parties to report any (suspected) improper conduct firstly to their regular contact at Euro Pool Group.  In case no contact is known or available, or reporting to this contact is not appropriate for any reason,  concerns can be reported (anonymously) to the Group Compliance Officer of Euro Pool Group:

Euro Pool Group

Attn. Group Compliance Officer

Laan van Vredenoord 8-12

2289 DJ Rijswijk, the Netherlands

T: +31 (0)70 301 4173

E: compliance.officer@europoolsystem.com

This policy covers any concerns about:

• conduct that is in breach of the (EU) laws or regulations, including in the areas of product safety (incl. legality, quality or integrity) and compliance, transport safety, damage to the environment, food safety, public health, consumer protection, privacy and personal data, and/or
• possible fraudulent or corrupt conduct, and/or  
• breaches of competition laws.

In case you have an enquiry or concern which does not relate to illegal or unethical behaviour or wrongdoing, please discuss this with your regular contact at Euro Pool Group.

Procedure for third parties

All concerns will be treated confidentially and if you ask for your identity to be protected, it will not be disclosed without your consent. All disclosures will be treated in a confidential and sensitive manner. Investigations into reported misconduct will be conducted in a fair and objective manner. The filing of a report does not guarantee that the matter will be formally investigated. All reports will, however, be assessed and considered by Euro Pool Group to determine if and if so, how, the conduct should be investigated.

When you file a report, you will receive an acknowledgement of receipt within seven (7) days after Euro Pool Group received the report, provided your identity, and contact details are known. Where reasonable and appropriate, a progress update will be provided. In any case, you will be informed of the status of the investigation and actions taken (if any) within three (3) months after Euro Pool Group received the report.

All suppliers, service providers, contractors and sub-contractors of Euro Pool Group and their respective employees who report their concerns in good faith will not suffer detrimental treatment in anyway, regardless of the outcome of the investigations. Deliberately raising false or malicious concerns, however, will be reviewed extremely seriously by Euro Pool Group.