Whistleblower Policy for Ambu

Ambu requires its employees, and representatives in any way to observe a high standard of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of Ambu, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

This whistleblower policy is intended to encourage and enable all customers, business partners as well as our own employees to raise serious concerns, so that Ambu can address and correct inappropriate conduct and actions. We consequently ask for your help in identifying areas for improvement, by reporting concerns about violations of Ambu’s code of conduct, anti-bribery policy or suspected violations of law or regulations that govern Ambu’s operations.

Scope

This policy is global, and applies to the entire Ambu group, defined as Ambu’ A/S and associated companies, affiliates of Ambu A/S or any entity that is directly or indirectly controlled by Ambu A/S, or is under common control or ownership with a party no matter the geographical location. The initiative is administered by and on behalf of Ambu A/S as the data controller.

What to report

You are strongly encouraged to take action promptly when faced with non-compliance with any Ambu policy or procedure, such as Ambu’s Code of Conduct or Anti-bribery Policy or any other applicable law or regulation. Examples may include:

• Financial fraud, criminal offence and other types of inappropriate financial practices or practices that raise questions about Ambu’s accounts, financial reporting, internal controls or auditing practices
• Misconduct of business practices and our Code of Conduct, which could constitute a conflict of interest. Corruption including payment of bribery or facilitation payments, unethical donations, gifts or entertainment to business partners given by Ambu employees
• Serious improper management including serious breaches of occupational safety, concerns about environmental pollution, serious issues directed towards an employee, for example, discrimination, violence or sexual assault or serious violation of local policies

It is in the best interest of Ambu that breaches of the Policies and Rules are reported. For this reason, Ambu will not tolerate retaliation against anyone who reports non-compliance with the Policies and Rules, regardless of whether or not their claim can be substantiated.

Cooperation and investigations

The Whistleblower Hotline is managed by an Audit Committee, which consists of three members The VP of Legal, the VP of Human Resources and the Corporate Compliance Officer.

If you wish to raise a concern through the Whistleblower Hotline, please use this link: https://ambu.whistleblowernetwork.net

You can write your report in your local language, if you don’t feel comfortable writing it in English.

In order to enable the Audit Committee to investigate the matter, you should explain and describe your concern in a reasonably detailed manner. The more information the Audit Committee receives, the easier it will be to initiate an investigation of the matter.

You should not attempt to conduct individual investigation to determine whether there has been a violation, but you should instead report suspected violations to the Audit Committee like described above.

Please be advised, that your report guarantees you anonymity. However, if you choose to write your name or contact information in the report, this is always appreciated as it makes an investigation easier. We will treat your reporting confidentially and protect your identity internally, if it is known to us. Only if a police investigation or other external investigations are needed, we might be required to reveal your name for them to assess all the information in the specific case.

The Audit Committee will upon receiving your report investigate the matter, and report to the CFO. The Chairman of the Board of Directors will receive reports on a 6 month basis, but will be informed on an ad-hoc basis as well. If it is needed, an independent external investigator may also investigate a concern.

The documentation relating to your report will be kept confidential and safe.

It is important to avoid innocent persons being suspected of irregularities that may constitute violation of the law or possibly misconduct. To this end, you should consider very carefully, whether the practices you intend to report are criticizable, before you initiate a report.

Are there any country-related restrictions?

The law of some countries imposes specific restrictions on reports, such as what may be reported, or whether or not a report can be submitted anonymously. These restrictions are incorporated into our Whistleblower Hotline:

• In Sweden, concerns may not be directed at employees, only management level officials
• In Finland you can only report financial matters (such as accounting, internal accounting controls, auditing matters, bribery, banking and financial crime)

Personal data issues and information

Ambu A/S (HQ), Baltorpbakken 13, DK_2750 Ballerup, Denmark, is data controller of the Whistleblower Hotline. Ambu will process your personal data in accordance with the General Data Protection Regulation (GDPR – EU) and the Danish Data Protection Acts supplementary provisions.

You may also contact us regarding any personal data issues by sending an e-mail to: dataprotection@ambu.com and you always have the right to file a complaint with the Danish Data Protection Agency (in Danish “Datatilsynet”), Borgergade 28, 5., 1300 Copenhagen, dt@datatilsynet.dk or your local Supervisory Authority.