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Whistleblowing Centre.

Skygard encourages all employees to speak up about concerns or report suspicions of possible violations of the law or the company’s regulations.The whistleblowing channel makes it easy and safe to report corruption, financial misconduct, and other illegal activities that occur within or are directed at the organization. The whistleblowing scheme allows reporting of matters one knows about or suspects are unacceptable. Whistleblowing means notifying someone who has the ability to handle the matter about objectionable conditions — this may include breaches of law, regulations, or social norms.Skygard aims to create transparency around such matters in order to correct unwanted situations and contribute to a safer and better organization.What is covered by the whistleblowing schemeThe scheme is designed for external parties such as users, suppliers, and others who have relations with Skygard. We encourage whistleblowing if there is knowledge of issues that may constitute breaches of laws or regulations, for example:

Corruption or financial misconduct such as embezzlement and theft

Conditions that may threaten life and health

Incidents that may harm the climate or environment

Abuse of authority

Breaches of personal data security

What is not considered whistleblowingExpressions concerning matters that relate solely to an employee’s own working conditions are not considered whistleblowing. Such matters are answered with a standard response and should be raised with the immediate manager.How to submit a whistleblowing reportWhistleblowing is carried out via an electronic form with an encrypted connection. When you submit the report, it is first handled by Skygard’s external whistleblowing reception. From there, the case is forwarded to the organization’s internal whistleblowing committee, which determines further handling. The external whistleblowing reception is operated by PwC Legal Services (Advokatfirmaet PwC AS).You do not need to document the matter beyond what you know, but you must describe the case as concretely as possible. The report should include, as relevant:

What happened?

Who was involved?

Where did it happen?

How was it discovered?

When did it happen?

Has it happened more than once?

Were there witnesses present?

Do you have documentation that can shed light on the matter?

Link to the whistleblowing channel: Reporting of concernsWhistleblowing via letter or emailLetter:
Sent to:
PwC v/ Fredrik Bergsmark Grimstad
P.O. Box 748, Sentrum
NO-0106 Oslo
Envelope marked: “Whistleblowing”Email:
Reports may be sent to: fredrik.grimstad@pwc.comAnonymity and accessWhistleblowers may remain anonymous if desired. Whether or not a name is provided, the case will be handled. However, it should be noted that handling is easier if dialogue with the whistleblower is possible. Therefore, if reporting anonymously, it is important to stay updated on potential dialogue in the whistleblowing channel after the report is submitted.To ensure due process, the person being reported about must normally be informed of the content and be given the opportunity to respond. If necessary to clarify facts, simple investigations may be conducted before informing the subject of the report. If the investigations show that no objectionable conditions exist, the case may be closed without informing the reported person.Skygard emphasizes both the safety of the whistleblower and the legal protection of the person being reported about.Processing after receiptWhen the report arrives at the external reception, it is assessed and categorized. The whistleblower will, if possible, receive confirmation of receipt. The case is then forwarded to Skygard’s whistleblowing committee.The committee assesses the further process based on the nature of the case. When the case has been processed, feedback is given to the whistleblower as far as possible.Confidentiality and public accessDocuments in whistleblowing cases are handled confidentially.