Whistleblowing

Contents

What cases should I report and how?

Handling and confidentiality of reports

Making a report

Hion operates responsibly and transparently

The whistleblowing procedure involves providing individuals who observe suspicions of misconduct, other violations, or actions contrary to regulations with a confidential channel through which an independent party can be reached. We take allegations of misconduct seriously and aim to offer an easy and confidential channel for their disclosure.

Following the guidelines below, employees, customers, or other stakeholders can report activities they suspect to be in violation of Finnish or EU legislation or in breach of Hion’s internal guidelines and principles.

What cases should I report and how?

We hope that you will raise any potential suspicions of misconduct. Such misconduct or violations may include fraudulent, dishonest, illegal, or unethical actions or behavior, or other actions that contravene rules or regulations.

Please note that the whistleblowing channel is intended solely for reporting allegations of misconduct. The reporting channel is not intended for providing customer feedback or making reclamations. For notifications unrelated to suspicions of misconduct, we kindly ask that you use the address info[at]hiondigital.com.

Handling and confidentiality of reports

Our whistleblowing channel is anonymous and based on a secure and encrypted service provided by WhistlePro (www.whistlepro.fi). The channel does not record information that would enable the identification of the sender. Reports submitted through the whistleblowing channel are only processed by designated individuals and the handling process is confidential. Confidentiality also applies when the reporter discloses their own identity.

When making a report, the reporter will receive a personal link, which should be saved and used to track the progress of the report and communicate with the handler.

Please note that after submitting a report, you need to save the link to your clipboard before proceeding to the conversation window. As the system does not store any information about you, we cannot send you a message when our handler responds to you. Therefore, remember to log into the system periodically to check the status of your report.

If you lose the link, you will no longer be able to access the old conversation. However, you can submit a new report, explain the situation, and continue the conversation with the handler through a new link.

Hion commits to thoroughly investigate all reports and take necessary actions based on the reports. All reports are processed promptly. No one who is the subject of the report or may have conflicting interests that could jeopardize the investigation will be involved in the inquiry.

The reporting channel must not be used for any purpose other than reporting legal or company policy violations.

The personal and other information provided in the reporting system will be treated confidentially and in accordance with applicable data protection legislation.

All reported information, including the identity of the reporter and the person subject to the report, may be disclosed to competent authorities, such as the police or the Financial Supervisory Authority, in accordance with applicable legislation.

Information included in the reports or obtained in connection with reporting may be used in internal investigations of violations. Only individuals who necessarily need access to the reported information to investigate the report can access and handle it within the company. Hion aims to keep this group of individuals as limited as possible. If prosecution occurs, the reporter will be notified that their identity may be revealed during pre-trial or court proceedings.

Making a report

1. Go to the Whistleblowing reporting channel at https://form.hailer.com/35709e7e6c7edaf5c3c2c98c7dd7d6de
2. Describe the issue you want to report. You can do this in either Finnish or English. Provide a comprehensive description of the problem so that we can investigate it thoroughly. Without sufficient or relevant information related to the reported issue, it may be difficult to investigate. Please do not include sensitive or personal information about any individuals mentioned in your report unless necessary to describe your concern or issue.
3. Your report should ideally include at least the following details:
   1. What is your concern? What matter(s) would you like to report?
   2. When did this occur?
   3. Where did this occur?
   4. Any other relevant information about the report
   5. You can use the upload button to attach files to your report if necessary for clarification.
4. Copy the link generated by the system for yourself, so you can add information, track the progress of the report, or communicate with the handler if needed.