Why whistleblow?

The whistleblowing function provides a secure and effective way to report suspicions of ongoing or past violations of legislation, misconduct, corruption, and irregularities. By making it easy to report, it allows us to address these cases, and together, we aim to promote trust from our employees, participants, customers, and the public.

This whistleblowing policy covers the legal entities in Yuncture AB, including Incubator, Yuncture Invest AB, and Yuncture House, Hammarviken Företagsutveckling AB, Hammarviken Fastigheter AB, Damacon AB, and Build Together AB, and others listed.

Who can report?

In simplified terms, you can report misconduct if you are or have been associated with Yuncture AB and its subsidiaries. If you are unsure, we encourage you to read more in our whistleblowing policy.

What can be reported?

We encourage you to blow the whistle if you suspect misconduct within the company that is of public interest. You do not need evidence for your suspicion, but all reports must be made in good faith.

How is the reporting handled?

Reporting is handled confidentially. All irrelevant personal information will be deleted, and the case will be retained only as long as necessary.

Full Policy

Background

At Yuncture AB, we aim to have an open and transparent workplace where misconduct should not occur.

The whistleblowing function provides a secure and effective way to report suspicions of ongoing or past violations of legislation, misconduct, corruption, and irregularities. By making it easy to report, it allows us to address these cases, and together, we aim to promote trust from our employees, participants, customers, and the public.

This whistleblowing policy is intended to be an interpretation and implementation of the following legislation:

EU Directive on Whistleblowing ((EU) 2019/1936)

General Data Protection Regulation ((EU) 2016/679)

Swedish Whistleblower Act (Law 2021:890)

1. Who can whistleblow?

You can whistleblow and receive protection under the Whistleblower Act if you are an employee, volunteer, intern, active shareholder, or someone otherwise available for work under our control and direction. Contractors, subcontractors, and suppliers who have learned about misconduct within the company can also report.

Ending your work-related relationship with us, or it not having started yet, is not an obstacle to reporting misconduct.

Additionally, we allow individuals outside the above categories to use our internal reporting channel. All reports will be treated equally, even if you, as an outsider, are not covered by the whistleblower protection provisions.

2. What can I whistleblow about?

If you suspect possible misconduct, legal and/or regulatory violations, we encourage you to report it as a whistleblowing case. It is important that at the time of reporting, you had reasonable grounds to believe that the information about the misconduct reported was true. The assessment of reasonable grounds should be based on circumstances and information available to you at the time of reporting. It is also important that the reported matter can be considered a violation eligible for whistleblowing and protection.

2.1 Misconduct of public interest You can report information about misconduct that has occurred in a work-related context and is of public interest. For other types of personal complaints that do not have public interest, such as disputes or complaints about the workplace or working environment, we encourage you to contact your immediate supervisor, HR, or another appropriate responsible person. This is to ensure that these matters are handled in the best possible way.

If it cannot be resolved at the company level, Yuncture AB welcomes you to use the whistleblower or contact our case handler. Contact details are provided later in this document.

NOTE! The following paragraph applies to companies with more than 250 employees and companies with 50–250 employees after December 17, 2023.

Examples of serious misconduct that should be reported include:

Deliberate incorrect accounting, internal financial control, or other financial crimes.

Incidents of theft, corruption, vandalism, fraud, embezzlement, or data breaches.

Serious environmental offenses or major safety deficiencies in the workplace.

If someone is subjected to serious forms of discrimination or harassment.

Other serious misconduct affecting individuals' lives or health.

Other serious misconduct affecting the company's vital interests.

More detailed explanations of the above adjustments can be found here: Explanation from Visslan & clarification from IMY regarding the processing of personal data on offenses

At Yuncture AB, we have chosen to consider all unethical or illegal behaviors as irregularities worth whistleblowing. Therefore, we treat all incoming reports equally, based on the intent of the law, and provide protection to all.

If the reporting does not meet the criteria of the Whistleblower Act, the law itself cannot provide protection. However, we will still provide the same confidentiality and protection against reprisals as for a legal report, provided that the report is true and/or made in good faith.

The following are examples of unethical or illegal behaviors that could be reported:

Actions and omissions that go against our culture, vision, and values.

Behavior that violates good practice and standards in the labor market.

Drug and alcohol abuse during working hours.

Dangerous actions that could cause physical harm to individuals or property.

Discrimination of any kind.

Abuse of position and/or abuse of power.

2.2 Violations of EU law Furthermore, there is the possibility to report information about misconduct in a work-related context that violates EU legal acts or regulations. If you suspect this, please read the Whistleblower Act §2 and the scope of the Whistleblower Directive in Article 2 and Annex Part 1 for applicable laws.

3. How do I report?

3.1 Written reporting In a written case, we use Visslan, our digital whistleblowing channel, which is always available at https://yuncture.visslan-report.se/. On the website, select "report" to describe your suspected misconduct. Please describe what happened in as much detail as possible so that we can ensure appropriate actions can be taken. It is also possible to attach additional evidence, such as written documents, pictures, or audio files.

It is easy to see which of the companies within Yuncture AB is the recipient of the report.

3.1.1 Sensitive personal data Please do not include sensitive personal data about individuals mentioned in your report unless it is necessary to describe your case. Sensitive personal data includes information about: ethnic origin, political opinions, religious or philosophical beliefs, membership in a trade union, health, a person's sex life or sexual orientation, genetic information, biometric information used to uniquely identify a person.

3.1.2 Anonymity You can remain anonymous throughout the process without affecting your legal protection, but you also have the option to disclose your identity under strict confidentiality. Anonymity may complicate the follow-up possibilities of the case and the actions we can take, but in such cases, we may later ask you to disclose your identity under strict confidentiality.

3.1.3 Follow-up and Login After you have reported, you will receive a 16-digit code, which you will be able to use to log in to Visslan at https://yuncture.visslan-report.se/. It is crucial that you save the code, as you will not be able to access the case without it.

If you lose the code, you can submit a new report referring to the previous one. Within seven days, you will receive a confirmation that the case manager has received your report. The case manager is an independent and autonomous entity that receives cases through the reporting channel, and their contact information is attached in "6.1 Contact Information for Case Manager."

For questions or concerns, you and the case manager can communicate through the platform's built-in and anonymous chat function. You will receive feedback within three months on any planned or implemented actions due to the reporting.

It is important that you, with your 16-digit code, log in regularly to respond to any follow-up questions the case manager may have. In some cases, the case cannot proceed without answers to such follow-up questions from you as the reporting person.

3.2 Oral Reporting It is also possible to conduct an oral case by uploading an audio file as an attachment when creating a case at https://yuncture.visslan-report.se/. You then select "Yes" to the evidence question to upload your file. In the audio file, you describe the same circumstances and details as you would in a written case.

In addition, a physical meeting with the case manager can be requested via Visslan. This is easiest done by either requesting it in an existing case or creating a new report.

3.3 External Reporting We encourage you to always report misconduct internally first. However, if difficulties arise or it is deemed inappropriate, external reporting is possible. In such cases, we refer you to contact the relevant authorities or, where applicable, EU institutions, bodies, or agencies. Contact information for these is available at www.visslan.com/resources/visselblasarpolicy/extern-rapportering.

4. What Are My Rights?

4.1 Right to Confidentiality During the case handling, it will be ensured that the identity of you as the reporting person is treated confidentially, and access to the case is prevented for unauthorized personnel. We will not disclose your identity without your consent unless applicable legislation compels us, and we will ensure that you are not subjected to reprisals.

4.2 Protection Against Reprisals Whistleblowers are protected against negative consequences resulting from reporting misconduct, in the form of a prohibition of reprisals. This protection applies even in relevant cases for individuals at the workplace assisting the reporting person, your colleagues and relatives at the workplace, and legal entities you own, work for, or otherwise are affiliated with.

This means that threats of reprisals and attempts at reprisals are not allowed. Examples of such reprisals include termination, changes in job duties, disciplinary actions, threats, discrimination, blacklisting within your industry, or similar actions due to whistleblowing.

Even if you are identified and subjected to reprisals, you are still covered by the protection if you had reasonable grounds to believe that the reported misconduct was true and within the scope of the whistleblower law. Note, however, that protection is not granted if it is a crime in itself to acquire or have access to the information reported.

Protection against reprisals also applies in legal proceedings, including defamation, copyright infringement, breaches of confidentiality, violations of data protection rules, disclosure of trade secrets, or claims for damages based on private law, public law, or collective labor law. You should not be held liable for any kind of consequences as a result of reports or disclosures provided that you had reasonable grounds to believe that it was necessary to report or disclose such information to expose misconduct.

4.3 Public Disclosure of Information The protection also applies to the public disclosure of information. It is assumed that you have reported internally within the company and externally to an authority, or directly externally, and no appropriate action has been taken within three months (in justified cases, six months). Protection is also granted if you had reasonable grounds to believe that there may be an obvious danger to the public interest if it is not disclosed, for example, in an emergency. The same applies when there is a risk of reprisals or it is unlikely that the misconduct will be remedied effectively, for example, in the risk of evidence being hidden or destroyed during external reporting.

Note, however, that this protection does not apply if you as the reporting person disclose information directly to the media in accordance with an otherwise applicable system of protection for freedom of expression and information. You still have whistleblower protection and acquisition freedom where applicable.

4.4 Right to Review Documentation at Meetings with Case Managers If you have requested a meeting with case managers, they will, with your consent, ensure that complete and accurate documentation of the meeting is preserved in a lasting and accessible form. This can be done, for example, by recording the call or by keeping minutes. Afterwards, you will have the opportunity to review, correct, and approve the minutes by signing them.

If the call was not recorded, case managers have the right to document the call through minutes. Afterwards, you will have the opportunity to review, correct, and approve the transcription by signing it.

We recommend that this documentation be kept in Visslan's platform by having the whistleblower create a case where information can be gathered securely.

5. GDPR and Handling of Personal Data We always do our utmost to protect you and your personal data. Therefore, we ensure that our handling of this data is always in accordance with the General Data Protection Regulation ("GDPR").

In addition to this, all personal data irrelevant to the case will be deleted, and the case will only be retained as long as necessary and proportionate. At most, a case may be processed two years after its completion.

6. Additional Contact If you have further questions regarding how we handle whistleblower cases, you are always welcome to contact the case manager.

For technical questions about the Visslan platform, please create a case at https://yuncture.visslan-report.se/.

If that is not possible, contact The Whistle Compliance Solutions AB, which developed Visslan.

6.1 Contact Information for Case Manager External Contact Person

Name: Mikael Mellberg Position: Lindahls Law Firm Email: mikael.mellberg@lindahls.se Phone: 0723 88 10 21

Internal Contact Persons

Name: Christoffer Rydhede Position: CEO Email: christoffer@yuncture.com Phone: 0704 95 23 61

Name: Månstråle Dahlström Position: Sustainability and Group Unity Email: manstrale@hammarviken.com Phone: 0723 41 59 80

6.2 Contact Information for The Whistle Compliance Solutions AB Email: clientsupport@visslan.com Switchboard: +46 10-750 08 10 Direct Number (Daniel Vaknine): +46 73 540 10 19

Definitions GDPR: General Data Protection Regulation, which is a European regulation that regulates the processing of personal data and the free flow of such data within the European Union.

Whistleblower Directive: Directive 2019/1936 on the protection of individuals reporting breaches of Union law.

Whistleblower Act: Act (2021:890) on the protection of individuals reporting breaches.

Visslan: The Whistle Compliance Solutions AB's service Visslan, enabling digital reporting of misconduct: https://visslan.com/.

Misconducts: Actions or omissions that have occurred in a work-related context where there is a public interest in them being revealed.

Reporting: Oral or written submission of information about misconduct.

Internal Reporting: Oral or written provision of information about misconduct within a company in the private sector.

External Reporting: Oral or written provision of information about misconduct to the relevant authorities.

Public Disclosure: Making information about misconduct available to the public.

Reporting Person: A physical person who reports or discloses information about misconduct acquired in connection with their work-related activities.

Reprisal: Any direct or indirect action or omission occurring in a work-related context prompted by internal or external reporting or public disclosure, causing or potentially causing unjustified harm to the reporting person.

Follow-up: Any action taken by the recipient of a report to assess the accuracy of the claims made in the report and, where applicable, to address the reported violation. This includes actions such as internal investigations, inquiries, legal proceedings, measures to recover funds, and the decision to discontinue proceedings.

Feedback: Providing reporting persons ("whistleblowers") with information about planned or taken actions as a follow-up and the reasons for such follow-up.