Aims of the Policy

Egmont is committed to honesty, decency, and accountability. In line with this commitment, we expect employees and business partners, who have concerns about Egmont's business, to come forward and voice their concerns.

Therefore, this policy aims to: 

• make you feel confident in raising concerns and help you question and act upon concerns about business practice 

• explain how you can raise those concerns 

• reassure you that you will be protected from reprisals or victimization if you have raised a concern in good faith

Scope of the Policy 

Concerns that may be reported under the whistleblowing policy include: 

1) Presumed breach of EU law, as set out in the EU directive no. 2019/1937 on the protection of persons who report breaches of EU law. 

2) Presumed serious breaches of national law. 

3) Other serious issues. 

The conduct of employees or other people in Egmont can be reported under the whistleblower policy. 

Any serious concern you might have concerning the conduct of managers, employees or other people in Egmont may be reported under the whistleblowing policy. 

If you are an employee and your concerns are about your salary or your terms of employment, you should contact your local management or local HR, and the matter will not be dealt with under the whistleblowing policy, unless the concern relates to a serious breach or other serious issues that take place at the workplace. 

How to raise a concern

If you are an employee, you should normally raise your concern with your own manager as a first step. If, however, you believe that your own manager is involved, you should approach your manager’s superior. If you believe your managing director or finance director is involved, you may choose to inform your division director.

If this is not possible, or if you are not employed in Egmont and have no access to relevant management levels within Egmont, you may log on to Egmont’s electronic whistleblowing system and send Egmont a message through the system. 

You will find your way to the system here: Whistleblowernetwork 

Your message will be read and processed by the responsible manager in Corporate HR and in Corporate Legal, unless they are subject to suspicion. In that case, the case will be handed over to an external investigator. 

In your message, please state the following: 

• the background and history of the concern 

• the reason why you are particularly concerned about the situation. 

The earlier you express your concern, the easier it is to take action. 

Although you are not expected to prove the whole truth of an allegation, you will need to demonstrate that there are reasonable grounds for your concern. 

Anonymous Allegations and Confidentiality

The Egmont whistleblowing system allows you to be anonymous – the system is especially designed for data protection and blocks both Egmont managers and the system provider from identifying the IP-address, from which the message has been sent. 

However, with this policy we encourage you to include your name in the breach report. Concerns expressed anonymously are less powerful than non-anonymous allegations.

All concerns will be treated in confidence and every effort will be made not to reveal your identity. 

Egmont does not tolerate any form of harassment, victimization or indirect pressure and will take appropriate measures to protect you if you raise your concern in good faith and have reasonable reason to believe that the report was needed to reveal a breach of law. 

How Egmont will respond

Egmont will acknowledge receipt of your report as soon as possible and at the latest within 7 days. In addition, we will make sure that you receive feedback as quickly as possible, and no later than within 3 months after you have received the acknowledgement of receipt of the report, on follow-up on the report and the reason for such follow-up. Feedback to you will be provided under observation of any other rules and regulations, including data protection legislation. 

Regardless of whether you choose to be anonymous or step forward with your name, you must register with a password of your own choice in the electronic whistleblowing system. The system will then send you a case number. If you wish to do so, you will from then on be able to communicate through the system with the responsible Egmont manager, using your case number and password to log in. You will be able to read and reply to messages sent to you by Egmont. 

Where appropriate, the matters raised may: 

• be investigated by management, internal audit, or through a disciplinary process 

• form the subject of an independent, internal investigation with external assistance if relevant. 

• be referred to the external auditor 

• be referred to the police 

In order to protect both the individual submitting the report and the persons concerned, initial enquiries will be made to decide whether an in-depth investigation is appropriate and if so, what form it should take. The overriding concern that Egmont will have in mind, is the interest of the Egmont Group and the public interest.

Some concerns may be resolved without the need for further investigation. If urgent action is required, this will be taken before any in-depth investigation is conducted.

If necessary, Egmont will seek further information from you through the electronic whistleblowing system. 

If a meeting is arranged, you may be accompanied by a representative from a union, a professional association, or by a friend. The meeting can also be held outside Egmont premises if you should so wish.

If your report is subject to whistleblower legislation applicable in the country in which you are employed, you will, from an employment perspective, be protected under that country’s rules on whistleblower protection. 

Untrue Allegations

If you make an allegation in good faith, which is not confirmed by the investigation, no action will be taken against you. If, however, you make an allegation frivolously, maliciously or for personal gain, disciplinary or legal action may be taken against you.

Information to Persons being reported under this Policy

Under the data protection legislation, Egmont can be under an obligation to inform the persons who have been reported under this whistleblowing policy that they are subject to an allegation, but not who has made the allegation. In that case Egmont will inform the persons concerned at the appropriate time, depending on the seriousness of the matter and the type of investigation needed.

The role of the responsible CEO and the board of directors

The CEO of Egmont has the overall responsibility for the maintenance and operation of this policy. The chairman of Egmont’s audit committee will be notified when records of concerns are raised. Egmont’s audit committee and the chairman of the board will receive quarterly updates and the board of directors will receive an annual record of concerns raised under the whistleblowing policy. If a matter concerns Egmont top management (Group CEO/CFO), or reports on serious/urgent matters, the audit committee and the chairman of the board will be directly informed. 

It will not appear from the records who has raised concerns, but only to whom or what the concerns relate.