Subject to any specific requirements of an applicable policy, law or regulation, Adform will handle complaints and investigations in the manner described below.

After a report is filed in the Whistleblower Scheme, a notification is sent to (i) Adform‘s SVP General Counsel and (ii) an entrusted lawyer of Kromann Reumert, who screens the submitted information. When the report is submitted, the individual will receive an automated acknowledgment of receipt. If a report is within scope of the Whistleblower Scheme, Kromann Reumert will send the report in accordance with the procedure set out under this Policy regarding financial matters and non-financial matters.

If the concern reported is considered to be outside of the scope of the Whistleblower Scheme, Kromann Reumert will inform the whistleblower that the report will be deleted. The report will not be forwarded to Adform. If a report is out of scope according to this Policy, it will not be submitted for investigation under the Whistleblower Scheme.

All cases, which are not obviously unfounded, will be investigated. Subject to the specific confidentiality obligation, external legal specialists within the subject matter reported will be consulted before any final decisions are made.

1. Financial Matters

Any report concerning Financial Matters will be brought to the attention of Adform's SVP, General Counsel, Chief Financial Officer (“CFO”) and Chairman of the Board of Directors. Upon receipt of such report, the SVP; General Counsel and CFO will undertake an investigation of the complaint; in the alternative, the CFO may subject to the specific confidentiality obligation appoint outside advisers or internal personnel to review, investigate, organize, collate or summarize any complaints before he or she undertakes an investigation.

After review by the SVP, General Counsel and CFO, he or she will discuss the findings with the Executive Management or the Chairman of the Board of Directors, as relevant, as promptly as practicable to determine whether any matters require additional investigation, a response or other treatment. Such action may subject to the specific confidentiality obligation include engaging outside advisors further or, where appropriate, delegating responsibility and disposition to appropriate company personnel.

2. Non-Financial Matters

Any report concerning non-Financial Matters will be brought to the attention of Adform’s SVP, General Counsel, Chief Human Resource Officer and Chairman of the Board of Directors, and, as necessary, the CEO and the applicable committee of the Board. Adform’s SVP, General Counsel and/or Chief Human Resource Officer will undertake a preliminary investigation to determine if the information can be substantiated and, as necessary, will advise the CEO, the Chairman of the Board of Directors and the applicable committee of the Board if any further action is required to fully evaluate the report. If so, Adform’s SVP, General Counsel and/or Chief Human Resource Officer will take action as it deems appropriate and as approved by the CEO, the Chairman of the Board of Directors and applicable committee of the Board. Such action may subject to the specific confidentiality obligation include engaging outside advisors or, where appropriate, delegating responsibility and disposition to appropriate company personnel.

Where deemed necessary and only for documentation purposes, Adform’s SVP, General Counsel and/or Chief Human Resource Officer will maintain an appropriate record of all communications and filings received and will track such communications and filings through his or her investigation and ultimate resolution. A periodic summary of such communications and filings will be made to the CEO, the Chairman of the Board of Directors or applicable committee of the Board.

3. Notification of Complaints

The Chairman of the Board of Directors, the CEO and the CFO will be apprised of the existence of any investigation, and they will be kept apprised of the status of the investigation regularly and in any case prior to the end of any reporting period for which the Chairman of the Board of Directors, the CEO and the CFO must provide written certifications and representations to the outside auditors, or any other applicable regulatory body. The whistleblower will not be kept informed about the progress and/or outcome of the submitted report.

4. Record keeping of reports received

Adform must keep record of your report and of all documents accompanying it.

Oral reporting is documented by recording the conversation or meeting in a durable and retrievable form with your consent, or by preparing accurate minutes of the meeting or the conversation with an opportunity for you to check, rectify and agree to the minutes by signing them. Oral reporting via the reporting system can be documented through an accurate transcript of the report with an opportunity for you to check, rectify and agree to the transcript by signing it.

Adform keeps such records subject to its non-disclosure obligation. Accordingly, Adform keeps records of your report in a manner that guarantees non-disclosure of e.g., your identity.

The purpose of the record keeping is, inter alia:

to preserve evidence of the reports received to ensure that the disclosures can be used as evidence in enforcement proceedings;
to safeguard the right of defence of the person concerned in connection with any criminal proceedings or other actions where the disclosures serve as evidence; and
to enable the linking together of information from multiple reports on the same matter, where such linking makes it possible to address and follow up on the matter and where this would not be possible based on a single report.

Records of your report will be kept in accordance with applicable data protection legislation.

5. Further documentation

If further documentation is necessary, it is possible for Kromann Reumert to contact you via the platform that was used for the reporting, also where you have opted to stay anonymous, provided that you have kept the line of communication open and answer any additional questions that may be asked via the platform. The documentation may include correspondence, documents, photos, minutes of meetings, telephone recordings, emails, expenditure sheets, browsing history, etc. If Kromann Reumert obtains further information from you and you opt to stay anonymous, then all your personally identifiable information will be deleted before the information is disclosed to the relevant persons at Adform.

6. Feedback to the whistleblower

Adform will give you feedback on your report as soon as possible and no later than three months after the date of acknowledgement of receipt.

Subject to compliance with applicable law, including the rules on non-disclosure, we will inform you of the action envisaged or taken as follow-up to the report and the ground for the choice of that follow-up. Follow-up could include, for instance, filing of a police report, launch of an internal enquiry, or referral to a supervisory authority.

If Adform has not, within three months of having acknowledged receipt of the report, decided on the follow-up action to be taken, you will be notified of this and of any further feedback you may expect.

7. Notification of persons concerned

Adform must inform the person concerned and any third party referred to in the report about the processing of their personal data in connection with the handling of a report unless this can be exempted. As a general rule, they must receive this information within a reasonable time, but at the latest within one month after the personal data have been obtained. However, provision of this information may be postponed or omitted, for instance for the purpose of investigating a matter, complying with the special duty of confidentiality, or safeguarding the interests of Adform or the whistleblower in question e.g. because of an ongoing investigation and/or perservation of evidence, including where such interests override the interests of the person concerned. Deviation from this obligation to provide information will be allowed if and to the extent provided in Article 14(5) of the General Data Protection Regulation or section 22(1) of the Danish Data Protection Act.

Our Commitment

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