Speak Up - Integrity Line Policy

Ambu requires its employees and representatives to observe and maintain the highest ethical standard of business and personal conduct of their duties and responsibilities. Employees and representatives of Ambu must practice integrity and transparency in fulfilling our responsibilities and comply with all applicable laws and industry regulations. Adherence to these principles will ensure our continued success and maintain the confidence of our customers and the communities in which we live. As a signatory of the UN Global Compact, Ambu works with the four principles on human rights, labour rights, the environment and anti-corruption, and contribute to the UN Sustainable Development Goals (SDGs). Ambu endorses international standards in key areas such as international human rights, business ethics and labor conditions. The Policy on Speak Up – Integrity Line aligns with the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct and and UN Guiding Principles on Business and Human Rights.

Policy statement

Ambu employees and business partners are strongly encouraged to take action promptly when faced suspicions or concerns about criminal offences, violations of Ambu’s code of conducts and policies, and other serious violations of law or regulations that govern Ambu’s operations done by Ambu employees or third parties interacting with or working on our behalf. The Policy on Speak Up – Integrity Line is intended to encourage and enable employees, customers, business partners, and stakeholders, within the company and along the supply chain to raise serious concerns or complaint about potential abuse or malpractice so that Ambu can prevent, detect, and correct inappropriate actions and misconducts.

Examples of areas where violations can be reported include, but are not limited to:

• Theft, embezzlement, fraud and falsifications
• Bribery and/or corruption
• Anti-trust/competition law
• Discrimination and harassment
• Major non-compliance with quality standards and procedures
• Conflict of interest
• Improper sales and marketing activities
• Violations of laws and regulations, including Ambu policies and procedures
• Major health, safety and environmental issue
• Human rights violations
• Insider trading
• Data Privacy and IT Security
• Trade sanctions

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 scope of the Policy is suspicions or concerns about criminal offences, violations of Ambu’s code of conducts and policies, including industry codes, and other serious violations of EU and/or local laws or regulations that govern Ambu’s operations (collectively, the Compliance Standards) done by Ambu employees or third parties interacting with or working on our behalf.

Hotline Committee

The Hotline Committee is the decision-making body for the Speak Up – Integrity Line, except in cases where reports are made about the members of the Hotline Committee (in such cases the decision-making body is the Executive Management).

The Hotline Committee consists of three members:

• Senior Director, Sustainability and Risk & Compliance
• VP, Global Legal & IP Affairs
• VP, Global People & Culture

General description

When reporting an issue, the Reporter is strongly encouraged to provide as much detail as possible, as it will enable the Hotline Committee to conduct a thorough and accurate investigation. The more information provided to the Speak Up – Integrity Line, the easier it will be to initiate an investigation of the matter.

The utmost care is taken to ensure protection of the confidentiality of the Reporter and there will be no retaliation, including discriminatory or disciplinary measures, against any Reporter using the Speak Up – Integrity Line to report a concern in good faith.

How to report

Cases can be reported by filing a written report online. Links to the Speak Up – Integrity Line can be found here https://ambu.whistleblowernetwork.net. Reporters can report cases in English or choose from the available language-options. Reports to the Speak Up – Integrity Line can be filed anonymously, except where prohibited by local law.

Countries where anonymous reporting is explicitly prohibited currently include Portugal and Spain. In Sweden, concerns must only be directed at management level. In Finland, only concerns about financial matters can be reported. In France, certain concerns, e.g. discrimination and harassment, may not be reported.

Personal data issues and information

Ambu A/S (HQ), Baltorpbakken 13, DK_2750 Ballerup, Denmark, is data controller of the Speak Up – Integrity Line. 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.