Summary of Mitta Group Oy’s Whistleblowing Channel

We at Mitta Group Oy as well as our subsidaries have a professional responsibility to speak up, report any possible corrupt, illegal or other undesirable conduct and take required actions after such conduct is discovered.

We strongly encourage anyone who conducts work for Mitta to speak up if one suspects or witnesses any such behaviour, activities or conduct.

Mitta Group Oy provides you with an effective, objective, confidential and secure reporting channel, the Whistleblowing Channel, allowing you to express your concerns openly and safely. The channel is available to you 24/7.

We take all reports seriously and we have a responsibility to protect you, including not disclosing your identity and ensuring you are not subject to any retaliations.

This page introduces Mitta Group Oy’s Whistleblowing Channel and summarizes Mitta Group Oy’s Whistleblowing Policy . If you wish to file a whistleblowing report, please carefully read the full Whistleblowing Policy prior to filing the report.

What can you report through our Whistleblowing Channel?

The Whistleblowing Channel is a channel through which you may report breaches specified in the Whistleblowing Directive (EU) 2019/1937, e.g. money laundering, offering or accepting bribes, and privacy-related breaches.

The Whistleblowing Channel is not intended for reports relating to employment law or working life. Do not report these through the Whistleblowing Channel. Please report these primarily to your closest superior.

Who can file a whistleblowing report?

You can file a report if you have had access to information on breaches by virtue of your work-related activities This includes, e.g. current and former employees, agency workers, job applicants, trainees, contractors and suppliers (or their employees or subcontractors).

How is your report handled?

In order to create a credible channel, ensure objectivity in the handling of reports and avoid reports being handled by a person who is in any way connected to the reported breach, Mitta Group Oy has decided to use the following third-party service providers to provide and maintain the Whistleblowing Channel. The technical whistleblowing platform is provided by Lantero AB and the preliminary review of the reports is done by HH Partners, Attorneys-at-law. Due to this chosen third-party service-provider arrangement, the persons who are authorized to receive and perform the preliminary review of your report are impartial, independent and professional. After a preliminary review, Mitta Group Oy’s representative will decide on any further investigation and action to be taken by Mitta Group Oy.

What protection is available to you as a whistleblower?

You are offered the following protections:

• protection of your identity, unless you have expressly indicated that your identity may be disclosed;
• protection against retaliation, meaning any negative consequences or threats or other attempts at retaliation;
• potential compensation and remedies for retaliation; and
• protection against civil, criminal and administrative liability.

Can you use the Whistleblowing Channel anonymously?

You can report anonymously through our Whistleblowing Channel. All reports filed through the Whistleblowing Channel are confidential, meaning that Mitta Group Oy is responsible for protecting your identity and the identities of any third parties mentioned in your report and has a legal obligation to keep your identity and the identities of any third parties mentioned in your report confidential.

The Whistleblowing Channel offers three options for handling your identity:

• you can remain completely anonymous and provide no contact details;
• you can provide only your email address;
• or you can disclose your identity.

Please note that if you provide your email address without choosing to disclose your identity, your email address will not be disclosed to Mitta Group Oy or the persons receiving and handling the reports. The Whistleblowing Channel will only use your email address to notify you of any communications between you and the person handling your report. Mitta Group Oy encourages you to provide at least your email address in line with the first option to ensure, e.g. that the report is handled effectively.

When do you receive protection as a whistleblower?

In order to receive protection:

• you have had access to such information on the breaches by virtue of your work-related activities;
• you have had reasonable grounds to believe that the matters reported by you are true and concern breaches that can be reported through the Whistleblowing Channel; and
• you comply with the three-step system requirement. The three-step system means that you report primarily through Mitta Group Oy’s Whistleblowing Channel, secondly through an external channel maintained by the Finnish Chancellor of Justice and only thirdly openly in public. Please note that you are only entitled to resort to the external channel (second stage) and open publication (third stage) in very limited circumstances and resorting to such channels without a legitimate justification will result in you losing the protection provided.

If you deliberately file a false report, you may be faced with employment-related consequences, such as a warning. In addition, criminal charges may be brought against you.