Grontmij believes it is important for our employees to have the possibility of reporting alleged irregularities of a general, operational and financial nature within the company without jeopardising their legal position.

This possibility is provided by the Whistleblowing Procedure, which is considered one of the safeguards of Grontmij’s integrity management system.

Key elements of the Whistleblowing Procedure
The Whistleblowing Procedure is adopted by the Executive Board. It provides Grontmij employees the possibility to report a reasonable suspicion regarding facts or circumstances that involve (the threat of):

a. a serious violation of Grontmij’s Business Policy, Business Principles and/or Code of Conduct;
b. a situation that exposes Grontmij to a liability in potentially significant amounts or to great reputational risk;
c. a hazard to public health, safety, society or the environment; and/or
d. the deliberate concealment, destruction or manipulation of information concerning the facts or circumstances as mentioned under a up to and including c.

In general, the Whistleblowing Procedure designates the Business Integrity Officer as the officer to whom shall be reported. Where a report concerns a member of the Executive Board, the report shall be made to the chairman of the Supervisory Board.

Employees may choose to report anonymously.

Reports will be treated confidential. The procedure contains strict provisions on who may be involved in the investigation of the report and who may be informed of the conclusions. The reporting employee’s identity - who did not report anonymously - will not be revealed, unless he or she expressly agrees thereto or legislation or a judicial decision obliges to disclose it.

The reporting employee will not suffer detrimental effects in his or her current or future position within Grontmij as a result of making the report. An exception to this is if the report relates to the reporting employee’s own acts or omissions, if it was made on false grounds and/or for the sole purpose of adversely affecting Grontmij or another employee or if the reporting employee seeks external publicity prior to completion of the Whistleblowing Procedure.

This information is posted on www.grontmij.com pursuant to II.1.7 Netherlands Corporate Governance Code.