At Skagen Salmon, we strive to foster an open and responsible corporate culture where employees, business partners, and other stakeholders feel confident reporting suspected irregularities, illegal activities, or other issues of concern. As an ASC-certified company, we are committed to conducting our operations transparently and in accordance with high standards for the environment, animal welfare, and social conditions.
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The whistleblower policy allows for the anonymous reporting of serious matters that may violate applicable laws, ASC requirements, or Skagen Salmon’s internal policies, regardless of whether they concern employees, management, customers, suppliers, or products. All reports are treated confidentially, seriously, and appropriately, and individuals who report a serious concern in good faith are protected against retaliation and similar actions.

Below, you can read more about the types of issues that can be reported via the portal. The full whistleblower policy is available on the portal itself.

The whistleblower policy may only be used to report serious irregularities or unethical conduct in connection with matters that may affect Skagen Salmon as a whole or the life and health of individuals.

There must be reasonable suspicion of a violation of laws or Skagen Salmon’s internal policies and guidelines.

Matters that may be reported through the whistleblower program may, for example, include reasonable suspicion of:

• Economic crimes such as embezzlement, bribery, fraud, forgery, and theft of goods and equipment, etc.

• Irregularities relating to accounting and auditing.

• Violations of competition law (e.g., price-fixing, exchange of price-sensitive information).

• Providing false or misleading information to public authorities.

• Serious threats to the environment and safety.

• Physical violence, sexual abuse, and health.

If you are unsure whether your observation should be reported, you are encouraged to do so. To the extent possible, the report should be supported by attaching relevant documentation in digital form. All reports submitted through the Whistleblower Program are taken seriously and will receive a response.

Matters that do NOT concern violations of legislation or Skagen Salmon’s internal policies and guidelines should not be reported via the Whistleblower Scheme. This applies, for example, to dissatisfaction with salary conditions, difficulties in collaboration, conflicts between colleagues and managers, etc.

Reports may only be submitted electronically (in both Danish and English) by completing and submitting an online questionnaire, which can be accessed via the link: https://skagensalmon.whistleportal.net/#/ on the Skagen Salmon website.

Reports made in bad faith through the whistleblower program, e.g., with the intent to harass or harm other employees, will result in sanctions and may lead to consequences under employment law.

All information is treated confidentially and with discretion.
BDO Statsautoriseretrevisionspartnerselskab has been appointed by Skagen Salmon as a data processor. BDO provides and manages the technical solution for the whistleblower program.

Reports submitted via the whistleblower portal are accessed by a few trusted employees at BDO, who receive and register the reports and forward them to Skagen Salmon’s management. If the report concerns Skagen Salmon’s management, the report is forwarded to Skagen Salmon’s Chairman of the Board.

It is possible to submit a report anonymously—and at the same time track the case using a 16-digit reference code, which is displayed after the report is submitted via the whistleblower portal.

It is possible to communicate anonymously afterward using the 16-digit reference code.

This communication channel will also be used to communicate any conclusion regarding the case to the reporter in the event that the reporter is anonymous. In cases where the reporter is anonymous, the following deadlines apply on the whistleblower portal:

• Acknowledgment of receipt of the report will be provided within seven days.

• The case will be processed as soon as possible, and every effort will be made to ensure that the processing does not exceed three months.

• A conclusion regarding the case will be communicated to the reporter via the anonymous communication channel.

• As a general rule, all cases are deleted from the whistleblower portal within 90 days of the reporting date, unless the deadline is manually extended by the recipient

• The reporter has access to the case via the whistleblower portal and the 16-digit key code until the case is deleted from the system. However, the reporter has access to the case for a maximum of one year from the date of reporting

Unless there are specific, substantial, and legitimate investigative considerations, the person to whom the reported information relates will be notified of the case’s progress once the report has been received and an investigation has been initiated.