Demant has established a whistleblower hotline, which enables employees, business partners and all other internal and external stakeholders to report any concerns about serious and sensitive matters confidentially and anonymously. We encourage employees and external stakeholders to raise their concerns about serious and sensitive actions that (1) fail to comply with our Code of Conduct, (2) fail to comply with applicable laws and regulations and/or (3) jeopardise the health and safety of our employees.

The whistleblower hotline enables employees, business partners and other stakeholders to report their concerns relating to corruption and bribery confidentially and anonymously. Group Legal & Compliance manages all reports received through the whistleblower hotline and our Whistleblower Policy and Investigation Guideline ensure that the investigator involved in a specific whistleblower case is independent from the chain of management involved in the matter.

Group Legal & Compliance manages the whistleblower hotline and has developed an Investigation Guideline, which is a tool that describes step-by-step how an investigation into a concern raised by an employee is conducted.

Group Legal & Compliance works closely with Global HR and has, in collaboration with them, developed an HR investigation process, which HR uses when conducting HR-related investigations. Employee concerns can also be reported to HR or managers directly and do not have to be reported through the whistleblower hotline.

We ensure that all employees are aware that they can safely report concerns through our whistleblower hotline. We have had several global campaigns promoting awareness about the hotline and, most recently, awareness was created through our global Code of Conduct and Whistleblower e-learning launched in H1 2024 in 11 languages.

Among other things, the e-learning informs the employees about the whistleblower hotline, how to report and what they can report and provides information about our anti-retaliation principles. In 2024, all employees globally were asked to complete the e-learning, and we plan to relaunch the e-learning every three years. In addition, the business ethics champions appointed in each subsidiary globally help raise awareness about the Code of Conduct and anti-corruption policy and guidelines, which apply to all employees globally, thereby assisting in the prevention of corruption and bribery through training.

In 2024, 58% of all Demant employees completed the e-learning. 76% of highly exposed employees, who are the target group for our 2030 target, completed the training.

Through anti-corruption risk assessment, we have identified the functions that are exposed to the highest risk in respect of corruption and bribery. These, among others, include employees that are in direct contact with public officials, for instance by participating in negotiations for public tenders on Demant’s behalf.

Anti-retaliation is a part of our Whistleblower Policy. We are committed to ensuring that there will be no discriminatory or retaliatory action against any employee or third party who in good faith raises a concern through the whistleblower hotline. Our anti-retaliation efforts comply with Directive (EU) 2019/1937.

Demant has implemented policies and guidelines to mitigate corruption risks throughout the organization. This includes an Anti-Corruption Policy, Gifts & Hospitality Guidelines, and country-specific appendices with local monetary limits and a Third Party Compliance Code, which contains a section on anti-corruption, and is included as an appendix in contracts with third parties. For third parties, a due diligence process is in place to assess the anti-corruption risk associated with dealing with third parties in scope of due diligence. Based on findings, appropriate mitigating measures are implemented, such as specific anti-corruption wording in the contract with the third party.

The investigator involved in a specific whistleblower case is independent from the chain of management involved in the matter.

Group Legal & Compliance reports regularly on material reports received through the whistleblower hotline to the audit committee and the Legal & Compliance Board.

The undertaking has implemented policies and guidelines to mitigate corruption risks throughout the organization, including an Anti-Corruption Policy and a Third Party Compliance Code.

Demant has established a whistleblower hotline, which enables employees, business partners, and other stakeholders to report their concerns relating to corruption and bribery confidentially and anonymously. Group Legal & Compliance manages all reports received through the whistleblower hotline and our Whistleblower Policy and Investigation Guideline ensure that the investigator involved in a specific whistleblower case is independent from the chain of management involved in the matter.