Whistleblower Policy

Policy Owner: Stina Hauschildt
Effective Date: 20250101

Purpose

The purpose of this policy is to provide a secure and transparent process for reporting serious misconduct within or related to Entwine AB. It ensures that concerns can be raised safely and confidentially, in line with the EU Whistleblower Directive and GDPR, while supporting our commitment to integrity and accountability.

1. Background

At Entwine AB, we are dedicated to fostering a transparent, ethical, and safe workplace environment. To support this, we have established a secure whistleblowing channel through our trusted partner Evity AB, which allows individuals to report serious concerns confidentially and, if they choose, anonymously.

This policy is designed in accordance with:

• The EU Whistleblower Protection Directive (EU) 2019/1937
• The General Data Protection Regulation (GDPR) (EU) 2016/679

2. Who Can Report?

The following individuals are eligible to report and receive protection under the whistleblower legislation:

• Current and former employees
• Job applicants, interns, and trainees
• Contractors, subcontractors, and suppliers
• Shareholders, board members, and volunteers
• Individuals who have not yet entered into a work relationship but gained relevant information during recruitment or negotiations

Additionally, Entwine AB allows others, such as external partners or customers, to submit reports. While they may not be protected under the law, we treat all reports with the same level of confidentiality and respect.

3. What Can Be Reported?

3.1 Serious Misconduct of Public Interest

You are encouraged to report suspected misconduct that poses a risk to public interest, such as:

• Financial crimes (e.g., fraud, bribery, insider trading)
• Corruption or misuse of company assets
• Environmental violations or safety risks
• Severe harassment, discrimination, or abuse of authority
• Serious breaches of internal controls or compliance policies

3.2 Violations of EU Law

Reports can also involve violations of EU regulations in areas such as:

• Public procurement
• Financial services
• Product safety
• Environmental protection
• Data protection and privacy

3.3 Exclusions

Personal grievances such as conflicts between employees, dissatisfaction with management, or minor HR issues should be raised through our regular channels, e.g., your immediate manager or Entwine AB’s management team.

4. How to Report

4.1 Via Evity HR

Reports are submitted securely through Evity HR’s whistleblowing platform. You can:

• Attach documents or other evidence
• Communicate anonymously with the appointed case manager
• Request an in-person meeting

All reports are handled independently by designated case managers at Entwine AB.

4.2 Anonymity and Confidentiality

You may choose to remain anonymous. If you identify yourself, your identity will be kept confidential and only disclosed if legally required. We prioritize privacy and data protection in all stages of the reporting process.

4.3 Follow-Up

After submission, you will receive a unique case ID to log in and track the status of your report. You will receive confirmation within 7 days, and feedback will be provided within 3 months.

5. Protection Against Retaliation

Individuals who report in good faith are protected from any form of retaliation. This includes:

• Dismissal or demotion
• Harassment or discrimination
• Withholding of promotion or benefits
• Threats or other forms of disadvantage

Protection also extends to colleagues, representatives, or relatives who assist in the reporting.

6. GDPR & Data Privacy

Entwine AB complies with GDPR in all whistleblowing procedures. Only data relevant to the case will be processed, and unnecessary personal data will be deleted. Cases are stored securely and only for as long as necessary, never exceeding two years after resolution.

For more information, please refer to Entwine AB’s internal data protection policy.

7. Contact

If you have any questions or concerns about this policy or the reporting process, you can reach out directly to:

Case Manager
Name: Stina Hauschildt
Email: stina@twine.se
Phone: +46737794059