Commitment to ethical and responsible business practices

Administer Group strives to be a good corporate citizen. Our goal is to achieve long-term profitability in our business by acting ethically and responsibly. We believe that by doing the right thing, we promote successful business operations and the well-being of both our customers and employees.

To further promote responsibility, please report any observed issues through Administer Group’s whistleblowing channel. These reports enable us to address potential problems and improve our operations. Administer Group’s whistleblowing channel applies to all companies within the group.

Introduction

The Administer Group’s whistleblowing channel is a means for reporting any misconduct you observe within our company. We recommend discussing any issues with your supervisor or the relevant person in our company first. If you prefer not to report to these individuals, you can use the whistleblowing channel.

The reports submitted through the whistleblowing channel are received and handled confidentially by authorized handlers appointed by the Administer Group. Only authorized handlers have access to the reports. The reports and any related internal investigations are conducted by a limited, specifically designated group of handlers.

We always protect the confidentiality of the identities of the whistleblower, the subject of the report, and any other parties mentioned in the report.

Whistleblowing Channel

EmCe Solution Partner Oy, a subsidiary of Administer Group, provides the whistleblowing channel used by Administer Group. Administer Oyj is responsible for the technical maintenance of the whistleblowing channel.

Submitting and Processing Reports

Submit a report if you suspect that a crime, misconduct, or any activity against the values of Administer Group has occurred. Reports can always be made anonymously.

When making a report, the whistleblower will receive a numerical code, which should be saved. This code allows the whistleblower to log into the whistleblowing channel to access their report and track its progress. The numerical code is the only way to access the report; if lost, a new report must be made.

There is no need to provide evidence to support the report. However, reports should always be made in good faith. Misuse of the whistleblowing channel and the deliberate submission of false or misleading reports is prohibited.

Sensitive personal data should not be included in the report unless it is essential for describing and processing the report. All reports are encrypted at the time of creation using strong symmetric and asymmetric encryption algorithms, which cannot be decrypted or altered afterward.

Administer Group has appointed an independent team to handle the reports. The persons responsible for handling the reports may request additional information from the whistleblower through the whistleblowing channel. Discussions related to the report can be conducted anonymously within the whistleblowing channel.

The handler will provide additional information within three (3) months through the whistleblowing channel about the actions taken based on the report. Reports and related internal investigations are conducted by a limited, specifically designated group of handlers. Other experts may also be used to ensure appropriate processing.

Reports are retained in the whistleblowing channel for one (1) year from the last active event between the Administer Group and the whistleblower. Information collected during the investigation will be deleted five (5) years after the start of the report’s processing unless retaining the information is necessary for the implementation of rights or obligations under the Whistleblower Protection Act or other laws, or the preparation, presentation, or defense of a legal claim.

Submitting a report to the Chancellor of Justice’s centralized Whistleblowing Channel

A report can be made to the centralized external whistleblowing channel of the Chancellor of Justice’s Office if the whistleblower has a justified reason to believe that the Administer Group will not address the matter effectively or if they fear retaliation. Information about the external whistleblowing channel is available on the Chancellor of Justice’s Office website.

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