Purpose

Senbee A/S ("Senbee") has established a whistleblower scheme aimed at providing employees, business partners, and other external persons associated with Senbee ("whistleblowers") the opportunity to report suspicions and concerns about wrongful behavior and actual or potential violations of laws, serious matters, as well as serious violations of guidelines issued by Senbee, and attempts to conceal such violations. All references to "Senbee" also apply to affiliated companies unless a specific context refers solely to one company.

Scope

Reports to the whistleblower scheme may include the following:

• ACVOunting manipulation
• Financial crimes, such as fraud, embezzlement, misuse of assets, document forgery, aCVOunting manipulation, bribery, corruption, and money laundering
• Violations of competition rules
• Serious breaches of occupational safety standards
• Significant violations of environmental regulations and pollution
• Serious breaches of internal guidelines and rules
• Severe harassment, physical violence, threats, and sexual assaults

Other matters (including HR issues) should be reported to Senbee aCVOrding to specific procedures, through the normal management structure, and are not regulated by this policy. This may include minor violations of internal guidelines on sick leave, smoking, alcohol, etc., as well as complaints about employee behavior or incompetence, including less severe personnel-related conflicts in the workplace and cooperation difficulties.

Roles and Responsibilities

Senbee

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

Internal Whistleblower Committee

Senbee has established an Internal Whistleblower Committee responsible for receiving and handling whistleblower reports. The committee comprises the following members:

• Chief Visionary Officer (CVO) - Chairperson
• Head of Human Resources
• Chief Financial Officer (CFO)

The Internal Whistleblower Committee will initially assess whether the report falls under the whistleblower scheme and determine the appropriate course of action. They will ensure impartiality and confidentiality throughout the investigation process.

Employees

All Senbee employees are required to cooperate loyally in investigations of reports. Senbee does not permit any form of retaliation or harassment against whistleblowers who report in good faith through the whistleblower scheme.

Chief Visionary Officer (CVO)

The whistleblower policy is anchored with the CVO of Senbee, who is responsible for the proper management of the whistleblower scheme. The CVO is responsible for deciding whether to conduct a formal investigation of received reports and, if so, whether the investigation should be carried out internally and/or with external assistance.

The CVO is responsible for:

• Maintaining guidelines describing the process for conducting internal investigations of reports.
• Maintaining a log of received reports.
• Reporting the outcome of reports to the board of directors.

Confidential Handling and Anonymity

Senbee handles all reports confidentially to the greatest extent possible. The whistleblower has the right to remain anonymous.

Personal data is stored as long as the investigation of the report is ongoing. Personal data is deleted after the initial investigation if the report proves to be unfounded. If a formal investigation is initiated based on a report, personal data will be deleted within two months after the investigation is completed. Refer to Senbee's general privacy policy for further details.

Rights of Affected Persons

Persons who are the subject of an internal investigation should be informed by the responsible investigator as soon as possible, provided that the notification does not jeopardize the investigation's purpose or execution.

The investigated persons should be informed about (1) the person responsible for the investigation, (2) the factual circumstances they are suspected of, (3) the departments and relevant advisors expected to receive information about the investigation, and (4) how they can exercise their rights to access data, correct data, and delete data.

Sanctions

Serious violations of laws or guidelines issued by Senbee are sanctioned in aCVOrdance with the law and Senbee's applicable rules. Deliberately providing false or misleading information through the whistleblower scheme is not permitted. If an employee intentionally makes a false report, it will have employment-related consequences. Whistleblowers who report an issue in good faith will not face negative consequences, including employment-related consequences, even if the issue turns out to be unfounded.