Whistleblower Policy

At Micro Technic A/S, we strive for an open company culture where everyone has the opportunity to report suspicions of irregularities or illegal activities, whether they involve employees, management, customers, suppliers, or products.

This policy allows employees to make anonymous reports in cases of reasonable suspicion regarding serious and critical matters or illegal activities. The policy ensures that such reports are handled seriously and appropriately while assuring that anyone who reports a serious suspicion in good faith will be protected from retaliation or similar consequences. Below is a general description of the matters that can be reported via the portal. The full policy can be read on the portal itself.

 

What Can Be Reported?

The whistleblower scheme can only be used to report serious irregularities or unethical behaviour related to matters that may affect Micro Technic A/S as a whole or individuals’ lives and health.
There must be a reasonable suspicion of violations of legislation or internal policies and guidelines at Micro Technic A/S.

Matters that can be reported through the whistleblower scheme include, for example, reasonable suspicion of:

Fraud/Economic Crime

• Economic crimes such as embezzlement, bribery, fraud, forgery, and theft of goods and inventory.
• Irregularities related to accounting and auditing.
• Violations of competition law (e.g., price-fixing, exchange of sensitive pricing information).

Production, General

• Providing false or misleading information to public authorities.
• Serious threats to the environment and safety.

HR

• Physical violence, sexual harassment, and health-related concerns.

If you are unsure whether your observation should be reported, you are encouraged to do so. If possible, the report should be documented by attaching relevant digital documentation. All reports made through the whistleblower scheme are taken seriously and responded to.

Matters that do NOT involve violations of legislation, internal policies, or guidelines at Micro Technic A/S should not be reported through the whistleblower scheme. This includes dissatisfaction with salary conditions or cooperation difficulties etc.

 

How to Submit a Report?

Reports can only be submitted electronically (both in Danish and English) by completing and submitting an online questionnaire, which can be accessed via the following link: https://[SITE].whistleportal.net on Micro Technic A/S’s website.

Reports made in bad faith through the whistleblower scheme, for example, with the intent to harass or harm other employees, will result in sanctions and may lead to employment-related consequences.

 

How Are Reports Handled?

All information is treated confidentially and discreetly.

BDO Statsautoriseret Revisionsaktieselskab has been appointed by Micro Technic A/S as a data processor. BDO provides and manages the technical solution for the whistleblower scheme.

Submitted reports via the whistleblower portal are accessed by a few trusted employees at BDO, who receive, register, and forward the reports to Micro Technic A/S’s management. If the report concerns Micro Technic A/S’s management, it will be forwarded to the chairman of the board.

 

How Are Reported Cases Processed?

It is possible to report anonymously and track the case via a 16-digit access code, which is provided after submitting the report through the whistleblower portal.

Anonymous communication is also possible using the 16-digit access code.

This communication channel will also be used to communicate the outcome of the case to the whistleblower if they have remained anonymous. In cases where the whistleblower is anonymous, the following timeframes apply in the whistleblower portal:

• A receipt confirming the report is issued within seven days.
• The case is processed as quickly as possible, and efforts are made to ensure that the processing time does not exceed three months.
• A conclusion on the case is communicated to the whistleblower via the anonymous communication channel.

As a general rule, all cases are deleted from the whistleblower portal within 90 days of the reporting date unless the deadline is extended manually by the recipient.
The whistleblower has access to the case via the whistleblower portal and the 16-digit access code until the case is deleted. However, the whistleblower can access the case for a maximum of one year from the reporting date.

 

Will the Reported Person Be Notified?

Unless special and significant investigative considerations apply, the person whom the report concerns will be informed about the handling of the case once the report has been received and an investigation has been initiated.