Whistleblower Policy

Senbee A/S ("Senbee") has established a whistleblower scheme to allow employees, former employees, applicants, board members, business partners, suppliers, consultants, contractors, trainees, volunteers, shareholders, and other persons with a work-related connection to Senbee to report concerns about serious wrongdoing, actual or potential violations of law, serious breaches of internal policies, and attempts to conceal such matters.

All references to "Senbee" also apply to affiliated companies unless a specific context refers solely to one company.

The purpose of this policy is to ensure that reports can be made safely, confidentially, and without fear of retaliation, and that reports are handled objectively, securely, and in accordance with applicable law.

Scope

Reports to the whistleblower scheme may include serious matters such as:

• Financial crimes, including fraud, embezzlement, misuse of assets, document forgery, accounting manipulation, bribery, corruption, tax offences, and money laundering.
• Violations of competition law.
• Serious breaches of occupational health and safety rules.
• Significant violations of environmental regulations or serious pollution matters.
• Serious breaches of data protection, information security, or confidentiality obligations.
• Serious breaches of internal policies, codes of conduct, or governance requirements.
• Severe harassment, discrimination, physical violence, threats, sexual harassment, or sexual assault.
• Attempts to conceal any of the above matters.

The whistleblower scheme is intended for serious matters. Ordinary HR matters, minor workplace conflicts, dissatisfaction with management decisions, cooperation difficulties, or minor breaches of internal guidelines should normally be reported through the usual management structure, HR procedures, or other relevant internal channels.

However, if an HR-related matter is serious, systemic, concerns senior management, involves retaliation, or cannot reasonably be reported through ordinary channels, it may fall within the whistleblower scheme.

How to Report

Reports can be submitted by contacting Senbee through the dedicated whistleblower channel: whistleblower@senbee.com

Reports should, where possible, include a description of the concern, relevant dates, persons involved, supporting documentation, and any other information that may help Senbee assess and investigate the matter.

Reports may be made anonymously. If a report is submitted by email from an identifiable email address, full anonymity cannot be guaranteed. Senbee will nevertheless treat the reporter's identity confidentially and restrict access to those who need the information to handle the report.

Whistleblowers may also report externally through the Danish National Whistleblower Scheme administered by Datatilsynet, where the matter falls within the scope of the Danish Whistleblower Act.

Roles and Responsibilities

Senbee

This whistleblower policy applies to Senbee A/S and all affiliated companies.

Whistleblower Committee

Senbee has established a Whistleblower Committee responsible for receiving, assessing, and following up on whistleblower reports. The committee consists of the following members:

• Chief Executive Officer (CEO) - Governance owner
• Chief Financial Officer (CFO)
• Chief Technology Officer (CTO)

The Whistleblower Committee is responsible for assessing whether a report falls within the whistleblower scheme, determining the appropriate follow-up, ensuring confidentiality, and documenting the handling of reports.

The committee must handle reports impartially and objectively. If a report concerns a committee member, or if a committee member otherwise has a conflict of interest, that person will not participate in receiving, assessing, investigating, deciding on, or reporting on the matter.

If a conflict of interest means that the report cannot be handled impartially by the remaining committee members, the matter may be handled by the board of directors and/or an external legal or professional advisor.

Employees

All Senbee employees are required to cooperate loyally and truthfully in investigations of reports. Senbee does not permit any form of retaliation, harassment, threats, discrimination, or other adverse treatment against whistleblowers who report matters where they had reasonable grounds to believe the information was true at the time of reporting.

Chief Executive Officer (CEO)

The whistleblower policy is anchored with the CEO of Senbee, who is responsible for ensuring that the whistleblower scheme is properly established, maintained, and reviewed. The CEO is responsible for the overall governance of the scheme, but reports may be received, assessed, and followed up by the Whistleblower Committee and/or approved external advisors.

If a report concerns the CEO, or if the CEO otherwise has a conflict of interest, the CEO will not participate in the handling, assessment, investigation, decision-making, or reporting of the matter. In such cases, the matter may be handled by the CFO and CTO, the board of directors, and/or an external legal or professional advisor.

The CEO is responsible for:

• Ensuring that the whistleblower scheme is maintained in accordance with applicable law and Senbee's governance requirements.
• Ensuring that appropriate procedures exist for receiving, assessing, investigating, documenting, and following up on reports.
• Ensuring that reports are acknowledged and followed up within the required timeframes.
• Ensuring that conflicts of interest are identified and managed.
• Ensuring that relevant outcomes are reported to the board of directors where appropriate, while preserving confidentiality, whistleblower protection, and data protection requirements.

Handling of Reports

Senbee will acknowledge receipt of a whistleblower report within 7 days, unless the report was made anonymously and no secure communication channel is available.

Senbee will assess whether the report falls within the whistleblower scheme. If the report does not fall within the scheme, the whistleblower may, where appropriate and possible, be informed about other relevant channels.

Reports that fall within the scheme will be assessed and, where necessary, investigated. The scope and form of the investigation will depend on the nature and seriousness of the reported matter.

Senbee will provide feedback to the whistleblower within a reasonable time and normally no later than 3 months after acknowledgement of receipt, unless this is not possible due to anonymity, legal restrictions, confidentiality, or the need to protect the investigation.

Confidential Handling and Anonymity

Senbee handles all reports confidentially and restricts access to persons who need the information to receive, assess, investigate, or follow up on the report.

The identity of the whistleblower will not be disclosed to unauthorised persons without the whistleblower's consent, unless disclosure is required by law, necessary for the protection of the rights of affected persons, or necessary in connection with legal proceedings or reporting to competent authorities.

Whistleblowers have the right to remain anonymous. However, anonymous reporting may make it more difficult for Senbee to investigate the matter, ask follow-up questions, or provide feedback.

Data Protection and Retention

Senbee processes personal data received through the whistleblower scheme for the purpose of receiving, assessing, investigating, documenting, and following up on reports.

Personal data will only be accessed by authorised persons and will be retained only for as long as necessary for the handling of the report, any investigation, documentation, legal obligations, potential legal claims, disciplinary measures, authority reporting, or other legitimate purposes.

If a report is clearly unfounded or falls outside the whistleblower scheme, personal data will normally be deleted or anonymised without undue delay, unless there is a legitimate reason to retain it. If a formal investigation is initiated, personal data will normally be deleted or anonymised when the matter has been finally closed, unless continued retention is necessary and lawful.

Further information about Senbee's processing of personal data is available in Senbee's general privacy policy.

Rights of Affected Persons

Persons who are the subject of a report or investigation have rights under applicable data protection law. These rights may include the right of access, rectification, deletion, restriction, and objection, depending on the circumstances.

Persons who are the subject of an internal investigation should be informed by the responsible investigator as soon as possible, provided that notification does not jeopardise the investigation, the preservation of evidence, the protection of the whistleblower, the rights of others, or any related legal or authority process.

Where notification is provided, the investigated person should be informed about the relevant factual circumstances, the purpose of the processing, the persons or categories of persons expected to receive information, and how they can exercise their data protection rights.

Protection Against Retaliation

Senbee prohibits retaliation against whistleblowers who report matters where they had reasonable grounds to believe the information was true at the time of reporting.

Prohibited retaliation includes dismissal, suspension, demotion, denial of promotion, changes to duties, negative performance treatment, harassment, discrimination, threats, blacklisting, contract termination, or any other adverse treatment connected to a whistleblower report.

The same protection applies to persons who assist a whistleblower, persons connected to the whistleblower, and persons or entities connected to the whistleblower where protected by applicable law.

Sanctions

Serious violations of laws, regulations, or guidelines issued by Senbee may result in disciplinary action, contractual consequences, reporting to competent authorities, legal action, or other appropriate measures.

Deliberately providing false or misleading information through the whistleblower scheme is not permitted. If an employee intentionally makes a false report, it may have employment-related consequences. Whistleblowers who report a matter where they had reasonable grounds to believe the information was true at the time of reporting will not face negative consequences, even if the concern later turns out to be unfounded.