Reporting Violations of the Code of Conduct

2. Draka’s viewpoint on reporting violations

2.1 Introduction

All employees that wish to raise a specific concern about violations of the Code of Conduct are encouraged to first discuss the matter with their direct manager or supervisor. This method is preferred because reporting of concerns to management is the fastest way to clear up any misunderstandings and also the best way to ensure an open working environment throughout the organization.
If this option is insufficient, the employee can report a suspected violation of the Code of Conduct to the Compliance Officer:
 
Ms. Jacoba Bremer
Address: De Boelelaan 7, 1083 HJ Amsterdam, the Netherlands
Email: complianceofficer@draka.com 

Alternatively employees could utilize an online reporting option. Please refer to the Draka Intranet site for more information on this option.

A suspected breach refers to a suspicion, based on a reasonable ground, which concerns the organization with:

a) Violation of external rules and regulation
b) Violation of internal rules and regulation
c) Unethical behavior

It will not always be clear whether a particular action falls under one of these categories and you will need to use your own judgment. However, in such cases, Draka would prefer that you report your concerns in good faith, rather than keep them to yourself.
Furthermore, the Whistle Blowing Procedure applies to all Draka companies and all its subsidiary companies worldwide.

2.2 Non-retaliation

Draka wants to ensure that an employee, who reports any breach that he or she reasonably believes to be true, can do so without the risk of retaliation. Employees who report a breach will be given protection and shall not be put at a disadvantage as a result of his or her report. If you have played a role in the irregularities, reporting this is however no guarantee that this will clear your name.

2.3 Misuse of Draka's Whistle Blowing Procedure

Draka wants to provide an environment in which employees can express any concerns they may have about wrongdoing at the workplace. We do welcome all reports made in good faith. If it should become clear that the Whistle blowing procedure has not been undertaken in good faith (for example, to pursue a personal grudge against another employee), this will constitute misconduct. Draka cannot permit a situation in which an employee purposely makes a report that he or she knows, or has reason to know, is false. Making a false report will most probably result in consequences for the employee, and he or she may be held accountable for damages suffered by anyone who has been affected by these false reports.