PROCEDURE FOR EXTERNAL REPORTING OF VIOLATIONS OF THE LAW AT HIAB POLAND SP. Z O.O.

( CONCERNS HIAB POLAND SP. Z O.O., HIAB POLAND SP. Z O.O. PRODUCT SUPPLY CENTRE, HIAB POLAND SP. Z O.O. CUSTOMER SERVICE CENTRE AND HIAB POLAND SP. Z O.O. CUSTOMER EXPERIENCE SUPPORT CENTRE)

• Violations that fall within the scope of Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of whistleblowers (the Directive) and the Act of 24 June 2024 on the protection of whistleblowers (the Act) are dealt with under the rules and procedure set out herein.
• A violation of the law covered by the Directive or the Act is an act or omission that is unlawful or intended to circumvent the law, relating to:
  • corruption;
  • public procurement;
  • financial services, products and markets;
  • anti-money laundering and combating the financing of terrorism;
  • product safety and compliance;
  • transport safety;
  • environmental protection;
  • radiological protection and nuclear safety;
  • protection of privacy and personal data;
  • security of ICT networks and systems;
  • the financial interests of the State Treasury of the Republic of Poland, of local government units and of the European Union;
  • the internal market of the European Union, including public law principles of competition and state aid, and corporate taxation;
  • constitutional freedoms and rights of a human being and a citizen – occurring in the relations of an individual with public authorities and not related to the areas indicated in points (a) to (l).
• In particular, conduct or action contrary to generally applicable laws, standards or internal regulations is considered to be:
  • any acts of corruption – including conflicts of interest, bribery, improper sponsorship, donations, gifts or entertainment exceeding acceptable standards of hospitality, illegal gratuities;
  • irregularities concerning accounting and financial reporting, internal accounting controls, audit matters;
  • financial fraud – for example, misappropriation, misuse of company assets, accounting manipulation, theft and misappropriation of assets or fraudulent financial statements;
  • competition law and antitrust violations – including price fixing, exchange of price-sensitive information, collusion with competitors;
  • collusion with third parties – any corrupt scheme at any stage of the process involving third parties, including requesting bribes, bid setting and fraud;
  • a serious threat to the environment, health and safety;
  • actions that constitute improper conduct or unethical behaviour under the law, treaties or agreements;
  • attempts to conceal any of the above facts
• Reports can be made by the Whistleblower, i.e:
  
  • a person providing work for HIAB Poland Sp. z o.o. on a basis other than employment relationship, including under a civil law agreement,
  • an entrepreneur,
  • a shareholder or partner,
  • a member of any governing body,
  • a person working under the supervision and direction of a contractor, subcontractor or supplier,
  • a trainee,
  • a volunteer.
• Hiab Poland Sp. z o.o. processes also anonymous reports.
• Hiab Poland Sp. z o.o. authorises the Corporate Ethics and Compliance Department to receive and process reports.
• Reports can be made in writing by contacting the Corporate Ethics and Compliance Department through the SpeakUp Line. The SpeakUp Line can be accessed via an external website or by typing https://cargotec.speakup.report/en-GB/Cargotec/home into a web browser. This address is specific to each separate organisational unit of Hiab Poland Sp. z o.o.
• The SpeakUp line enables the reporting of irregularities and communication with the Whistleblower.
• The SpeakUp line is a channel that allows the Whistleblower to remain anonymous while the report is being processed. The Corporate Ethics and Compliance Department assigns a number to the report and thereafter the report is dealt with while maintaining the anonymity of the Whistleblower.
• Reports sent outside the SpeakUp Line will be forwarded to the Corporate Ethics and Compliance Department for processing through the SpeakUp Line.
• The Corporate Ethics and Compliance Department reviews the report and assesses the need for an investigation.
• The Corporate Ethics and Compliance Department confirms to the Whistleblower the acceptance of the report within 7 days of its receipt, unless the Whistleblower has not provided a contact address to which the confirmation should be forwarded.
• The report should specify, in particular:
  
  • the identity of the person(s) who committed or contributed to the irregularity which is the subject of the report;
  • data of persons who are or may become victims of irregularities that are the subject of the report (who have suffered or may suffer financial, material, psychological and/or physical loss):
  • what the reported violation/irregularity consisted of, and the circumstances in which it occurred.
• The Whistleblower does not have to provide his or her personal data.
• The report may be documented by collected evidence and a list of witnesses.
• Making false reports, using the reporting of violations in bad faith or in a manner that violates the personal interests of the person to whom the Report relates, particularly those of a slanderous or incriminating nature, is unacceptable and shall not be protected by law.
• The Corporate Ethics and Compliance Department notifies the Whistleblower of the findings of the investigation carried out and the decision taken by providing feedback. Feedback shall include, in particular, information on whether or not a violation of the law has or will be established and on the measures, if any, which have been or will be taken in response to the established violation.

In Polish