Reporting violations

Our Group’s reputation for being an honest, fair and capable firm with which to do business is one of our most valuable assets we are determined to preserve.

For an effective enforcement of the Code of Conduct, the Company expects anyone who becomes aware of a case of non-compliance with the Code within the Group to report the violation.

All employees should report any violation or suspected violation to their direct manager/supervisor or, in cases when this may be ineffective or inappropriate, they should contact the Human Resources Department and/or the General Manager and/or the Managing Director of their company, or directly the Compliance Office / Officer (Compliance Office) of their Company or, in absence of it, the Compliance Officer of PVM Group BV.

When a violation report is submitted to the informant’s manager/supervisor or to the Human Resources Department or to the General Manager and/or Managing Director or to the Compliance Office, the Management of the Company involved shall immediately conduct investigations and, if necessary, apply the appropriate disciplinary measures.

The Compliance Office is a body appointed by the Board of Directors of the Operating Company and vested with initiative and control powers. The Compliance Office shall verify the reported information promptly and carefully, and, if it is found accurate, shall submit the case to the appropriate Manager/Function responsible for applying any disciplinary measure or terminating the offender’s employment contract. The Compliance Office may summon and interview the informant and any other parties involved, in consultation with the Management of the Company involved (General Manager and/or Managing Director), if appropriate.

Third parties shall address their notice of violation directly to the Compliance Office of PVM Group B.V.

Reports to the Compliance Office of PVM Group B.V. should be made in writing and sent to either of the following addresses:

The Group shall make sure that no one who reports an actual or attempted violation to the Code of Conduct is subject to any form of retaliation, illicit conditioning, harassment or discrimination at the workplace, as a consequence of his/her reporting a violation of the Code or of any internal procedure.

Any form of reprisal against persons who, in good faith, report violations of the Code of Conduct, constitutes a violation of this Code as well. Accusing other employees of a violation with the conscious knowledge that the accusation is false is also a violation of the Code of Conduct.