Whistleblower Policy

Acendae B.V.

Effective Date: July 2026

1. Introduction

At Acendae, we are committed to maintaining a culture of integrity, transparency and accountability. We believe that everyone working with or connected to Acendae should feel safe and supported when raising concerns about potential misconduct, violations, or unethical behaviour.

This Whistleblower Policy explains how individuals can report suspected wrongdoing, how reports are handled and what protection is provided to individuals who raise concerns in good faith.

Acendae is committed to ensuring that all reports are handled:

• Confidentially
• Fairly
• Independently
• Without retaliation against the person reporting the concern

This policy may be updated periodically to reflect changes in applicable legislation or Acendae’s internal procedures.

2. Purpose of This Policy

The purpose of this Whistleblower Policy is to:

• Encourage early reporting of potential misconduct
• Provide a safe reporting mechanism
• Protect individuals who raise genuine concerns
• Ensure concerns are investigated appropriately
• Support compliance with Dutch and European laws

A person reporting a concern is not required to prove wrongdoing before making a report. However, the report should be based on reasonable grounds and information obtained through a work-related context.

3. Who Can Report a Concern?

A report may be submitted by anyone who obtains information about possible wrongdoing through their professional relationship with Acendae.

This includes, but is not limited to:

• Employees
• Interns
• Freelancers
• Contractors
• Consultants
• Job applicants
• Former employees
• Suppliers
• Business partners
• Clients
• Shareholders or other stakeholders

Protection may also apply to individuals who assist the reporter, such as advisers, colleagues, or family members where applicable under Dutch law.

4. What Can Be Reported?

Reports under this policy may relate to suspected violations including, but not limited to:

5. Matters Not Covered Under This Policy

Not all workplace concerns fall under whistleblower protection.

Examples include:

• Personal workplace disagreements
• Individual employment disputes
• Salary discussions
• Performance concerns
• Normal workplace complaints

Such matters should normally be addressed through the appropriate channels, such as:

• Direct managers
• Human Resources
• People & Culture representatives

Reports made purely for personal benefit or knowingly containing false information may not receive protection under this policy.

6. Protection of Whistleblowers

Acendae prohibits any form of retaliation against individuals who report concerns in good faith.

A whistleblower will not be disadvantaged because they have submitted a report, including through:

• Termination of employment
• Negative performance treatment
• Demotion
• Reduction of responsibilities
• Unfair treatment
• Threats or intimidation
• Financial disadvantage

Protection applies where the report is made:

• In good faith
• Based on reasonable grounds
• Following the procedures described in this policy

Protection may not apply where a person:

• Intentionally provides false information
• Makes malicious accusations
• Obtains information through unlawful actions

7. Confidentiality and Privacy

Acendae will handle all reports with strict confidentiality.

The identity of the whistleblower will only be shared with individuals who need the information to properly investigate and manage the report.

Acendae will not disclose the identity of the reporting person unless:

• The whistleblower provides consent
• Disclosure is required by law
• Disclosure is necessary as part of legal proceedings

All personal data collected during the reporting process will be processed in accordance with:

• The General Data Protection Regulation (GDPR)
• The Dutch GDPR Implementation Act (Uitvoeringswet AVG)
• Acendae’s Privacy Policy

8. How to Submit a Report

Reports can be submitted through Acendae’s designated reporting channels.

A report may be submitted:

• In writing
• Verbally
• Through a confidential meeting request

Reports may be made anonymously where the available reporting channel supports anonymous communication.

When submitting a report, the whistleblower should provide:

• A clear description of the concern
• Date, location and circumstances where possible
• Names of individuals involved
• Supporting documents or evidence where available
• Contact details if the whistleblower wishes to receive updates

9. Internal Reporting Procedure

1. 1.

   Receipt of Report

   After receiving a report, Acendae will:

   • Confirm receipt within seven days where possible
   • Review whether the report falls within the scope of this policy
   • Assign appropriate persons to handle the matter

   Anonymous reports will be handled to the extent possible based on the information provided.

2. 2.

   Investigation Process

   Acendae will ensure that investigations are conducted:

   • Objectively
   • Independently
   • Confidentially
   • Without unnecessary delay

   Depending on the nature of the report, Acendae may involve:

   • Management representatives
   • HR / People & Culture
   • Legal advisers
   • External specialists

   Individuals involved in the reported matter will be treated fairly and given appropriate opportunity to respond.

3. 3.

   Feedback and Outcome

   Where legally permitted and reasonably possible, the whistleblower will receive updates regarding:

   • Confirmation of investigation progress
   • Actions taken
   • Final outcome

   Acendae aims to provide feedback within three months after confirmation of receipt of the report.

10. Corrective Actions

If an investigation confirms misconduct or a violation, Acendae will take appropriate action.

Possible actions may include:

• Corrective measures
• Process improvements
• Additional training
• Disciplinary actions
• Legal action where required

The action taken will depend on the seriousness and circumstances of the matter.

11. External Reporting

Individuals are encouraged to raise concerns internally first where appropriate. However, Dutch law also allows whistleblowers to report certain concerns directly to competent external authorities.

Depending on the nature of the concern, relevant Dutch authorities may include:

The appropriate authority depends on the nature of the reported issue.

12. False Reports

Acendae encourages genuine reporting of concerns.

However, knowingly submitting false, misleading, or malicious reports may result in appropriate action.

Making a report that is unsuccessful does not automatically mean the report was false. Protection remains available where the report was made honestly and with reasonable grounds.

13. Responsibility and Continuous Improvement

Acendae regularly reviews its reporting procedures to ensure they remain effective, accessible and compliant with applicable Dutch legislation.

Employees and stakeholders are encouraged to contribute to creating a workplace culture based on:

• Trust
• Respect
• Transparency
• Accountability

14. Contact Information

For questions regarding this Whistleblower Policy or to submit a concern, please contact:

Acendae B.V.

Netherlands

Email: [email protected]

Website: www.acendae.com