In line with our values and vision, and with due regard for the interests of our stakeholders, we are committed to preventing and detecting unlawful conduct. The use of whistleblowing is an effective method for this. It enables employees to report suspicions and doubts about fraudulent activities without fear of retaliation. The Whistleblowing Policy is essential to achieve the following goals:

• Promoting a culture of openness, accountability, and integrity;
• Creating a safe environment in which whistleblowers can report breaches, misconduct, or negligence that could affect the integrity of Vytech or lead to financial loss or reputational damage, without fear of retaliation;
• Increasing awareness among employees about the existing channels within Vytech for reporting suspected or actual breaches;
• Increasing the likelihood that management is alerted to breaches at an early stage and can take appropriate measures;
• Guaranteeing confidentiality and the protection of the legitimate personal interests of whistleblowers when reporting potential breaches;
• Ensuring compliance with the principles regarding the investigation procedure as laid down in the Whistleblowing Policy.

This Whistleblowing Policy is based on the regulations set out in the EU Whistleblowing Directive (Directive (EU) 2019/1937) and its transposition into local legislation.

In accordance with the Whistleblowing Act, reports can be made if one believes in good faith that they constitute a breach in the following areas:

The scope is defined in Article 2 of the Belgian Whistleblowing Act and includes reports of breaches of European or national legislation in various domains such as public procurement, financial services, product safety, environmental protection, public health, and consumer protection.

Reports may relate to breaches that harm the financial interests of the EU or breaches relating to the internal market.

The competent authorities for external reports are listed in the Royal Decree of January 22, 2023.

Within 7 days of receiving the report, the reporter will receive an acknowledgment of receipt. No later than three months after the acknowledgment of receipt, the reporter will receive feedback on the planned or taken measures and the reasons for them.

Whistleblowers acting in good faith will not be subject to any form of retaliation. If it appears that the whistleblower has not acted in good faith, disciplinary or legal measures may be taken.

If the alleged facts are confirmed, disciplinary measures may range from a warning to dismissal, depending on the severity of the breach. In cases of insufficient evidence, corrective measures may be taken to prevent recurrence.

Whistleblowers who make reports in good faith are protected against unjustified retaliation. This includes measures such as suspension, demotion, intimidation, or discrimination. Complaints about retaliation are taken seriously and investigated if necessary. This protection also applies to persons who have assisted the whistleblower.

This Whistleblowing Policy does not apply to personal work-related concerns or commercial decisions of Vytech. For such matters, regular internal channels should be used. If the matter cannot be reported through these internal channels, the Whistleblowing Policy applies.