ad pepper media International N.V, with all its affiliates and its group companies (together the “Company”) is committed to conducting its business honestly and with integrity. We expect all employees, as well as third parties (including temporary and contract employees), managers, and consultants, interns, expatriate representatives and agents acting on behalf of the Company, to maintain high standards and uphold the values and behaviours set forth in our Global Standards of Business Conduct (or “Code of Conduct”) retrievable under our website https://www.ad-agents.com/en/code-of-conduct/.

This reporting guideline is based on the German law which transposes the EU Whistleblower Directive EU 2019/1937 into national law. It refers to concerns regarding suspected or actual criminal conduct, unethical behaviour or other misconduct, including a (suspected) breach of (EU) law by or within the Company, such as for example:

• violations of the Code of Conduct of ad pepper media International N.V.,
• employment law violations, including discrimination and harassment in the workplace,
• violations of accounting, internal accounting controls or audit matters,
• money laundering or terrorist financing,
• financing customers who violate human rights or commit environmental crimes,
• market manipulation,
• insider Trading,
• violations of public procurement, financial services, product and transport safety, environmental protection, public health and consumer protection (in accordance with EU Directive 2019/1937),
• breaches of confidentiality or data protection,
• theft,
• fraud,
• fribery or corruption,
• unwanted behavior,
• violations of other laws, regulations or guidelines of the Company.

The purpose of our Whistleblower Reporting Guideline is to:

• promote reporting, as required by our “Code of Conduct” for business practices, of any suspected fraud or corrupt conduct or any other form of improper behavior, including possible violations of our Code of Conduct; provide guidance on how to report concerns internally and externally;
• confirm that confidentiality will be maintained and that concerns expressed in good faith can be raised without fear of retaliation, even if they later prove to be groundless;
• acknowledge that whistleblowers are protected by law and that they are protected from legal sanctions if they act in the public interest and follow established procedures.

How to report concerns

Reports of concerns about possible violations of the Code of Conduct and of the matters listed in the Whistleblower regulations can be reported at any time through Company’s internal and external whistleblowing channels to raise these concerns (also anonymously) without fear of retaliation.

To submit a report, please copy the following URL into your browser. This allows concerns to be raised (anonymously if desired) without fear of retaliation.

After the concerns are received by the Company, a receipt will be sent within 7 days. Such reply will provide acknowledgement of receipt and the status and results of the investigation, if any, in a language understandable to the whistleblower (generally English). Based on the information provided, whistleblowing concerns will be investigated. The whistleblower has the right to be informed of the progress and results of the investigation. However, this may only be done when it does not affect internal inquiries or investigations and does not affect the rights of the people who are the subject of a concern or who are named in the report. The Company may seek subsequent contact if it deems it necessary to obtain further clarification; contact is sought through available (anonymous) communication channels (Should a concern be reported anonymously, the Company will give feedback and communicate with the person providing the information only through the online reporting tool if possible). An update on the follow-up of concerns will be shared within three (and in exceptional cases up to six) months after the acknowledgement of receipt.

Confidentiality

The Company will take all reasonable precautions to keep confidential the identity of those who raise concerns. The report will only be read and processed by authorized persons who are bound to confidentiality. The Company will not process any personal data of the whistleblower without the whistleblower’s express consent, unless required by law.

Protection

The Company is committed to ensuring that no one is disadvantaged in any way for raising, legitimately and in good faith, concerns about suspected facts or conduct. This explicitly includes retaliation. Specifically, the person(s) reporting concerns must not be disadvantaged by termination, demotion, loss of benefits, threats, harassment, discrimination, or bias. Such retaliation is prohibited and those who take such actions may be held responsible. Retaliation may have criminal consequences under the Whistleblower Regulations.

However, this Whistleblower Reporting Guideline does not legitimate any abuse, or any reporting made with bad faith or solely aimed to discredit others’ reputation.