External Whistleblowing Policy 

Policy Owner: People and Culture 
Effective Date: December 2023 

EasyPark Group requires executives, board members, managers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. 

We practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations, globally. Our Whistleblowing tool is extended towards external parties for reporting potential breach of ethics in the conduct of our duties and responsibilities.

Reporting Responsibilities 

This Whistleblower Policy is intended to encourage and enable board members, officers, employees, independent contractors, third-party vendors, customers, business partners and volunteers to make EasyPark aware of any practices, procedures or circumstances that raise concerns including but not limited to: 

  • Concerns regarding the integrity of EasyPark’s financial disclosures, books and records 

  • Suspected or actual violations or infringements of applicable national or foreign laws or regulations, as well as of internal company policies

  • Anti-bribery and corruption offenses (such as accepting or offering money or other items of value in order to obtain a contract or gain positions of favor)

  • Violations of company data protection and information security policies.

  • Misconduct with regard to competitors 

  • Property offenses 

  • Discrimination and bullying 

This Policy is to be read in conjunction with EasyPark’s Code of Ethical Business Conduct and Code of Conduct, which describe requirements and best practices relating to business practices and personal conduct. Any violations of this policy or these codes of conduct, should be promptly reported. 

Reporting Procedures 

We encourage board members, officers, employees, independent contractors, third-party vendors, customers, business partners and volunteers to raise concerns as early as practicably possible to seek resolution in a timely manner.  

All incidents shall be reported via the whistleblowing tool provided by EasyPark

Reportees can expect their submission to be reviewed within seven business days, and EasyPark will be responsible towards taking actions and informing about status, investigation and outcome within three months following submission

At EasyPark, the nominated representatives are Head of People Operations and SVP, Human Resources and/or the company’s General Counsel or regional Deputy General Counsel.  

Confidentiality and Handling of Reported Violations 

Once a report has been received, EasyParks representatives will initiate a confidential investigation including, but not limited to, gathering information, speaking with potential witnesses or other impacted employees, and reviewing documents, records and other data as needed. Only those on a ‘need-to-know’ basis will be informed about the report and have access to this information. If the report was not made anonymously, you will hear back from the assigned team promptly that an investigation has been initiated and with any questions requiring more information from you. 

EasyPark is not obligated to protect the confidentiality and anonymity of a non-employee person who submits a complaint unless the disclosures made have a connection to the wider public interest. 

If your report was not anonymous, EasyPark will protect your confidentiality and identity to the fullest extent possible, consistent with the need to conduct an adequate review and investigation of your complaint. There may be circumstances where the information needs to be disclosed to third parties, including other employees of EasyPark, law enforcement, or auditors, in order that the information may be properly investigated as part of any disciplinary or criminal proceedings and reported as may be required by applicable law. 

At the conclusion of the investigation, appropriate corrective action will be taken if warranted by the investigation. The involved parties will be informed that the matter was investigated and handled, though EasyPark will not be at liberty to disclose the exact nature of corrective actions taken, if any. 

Acting in Good Faith 

Anyone filing a complaint concerning a violation or suspected violation of company policies or applicable laws must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and to have been made maliciously or knowingly to be false will be viewed as a serious offense. Such an offense could be subject to disciplinary action, including termination of employment.

No Retaliation 

It is against the values of EasyPark for anyone to retaliate against someone who in good faith reports a suspected violation under this Policy. 

EasyPark will not discipline, discriminate against, or retaliate against any person who reports a complaint in good faith, and will abide by all laws that prohibit retaliation against employees who lawfully submit complaints under this Policy. 

An employee who disciplines, discriminates against, or retaliates against someone who reported a violation in good faith may be subject to formal disciplinary action, including termination of employment. 

Handling of Records and Data 

All reports and records associated with complaints under this Policy are considered confidential information. All complaints and documents relating to such complaints made through the procedures outlined in this Policy shall be retained for at least five (5) years from the date of the complaint, after which time the information may be destroyed unless the information may be relevant to any pending or potential litigation, inquiry or investigation, in which case the information may not be destroyed and must be retained for the duration of that litigation, inquiry or investigation and thereafter as necessary. 

Periodic Reviews and Amendments 

The People & Culture and Legal Departments will periodically review and update this Policy.