GN’s Group Business Ethics & Compliance department collaborates with the entire organization to mitigate risks of non-compliance with anti-corruption laws and GN policies. The commitment to business ethics is anchored in GN’s Ethics Guide, which outlines the responsibilities and ethical standards expected of all employees and relevant business partners. Standards, policies, and training programs play a critical role in preventing potential misconduct across GN. Additionally, it outlines a decision-making process that supports the resolution of ethical issues and identifies GN departments who are available to help and advice. Case studies are provided to illustrate how ethical responsibilities and guidelines apply in everyday situations. Key content includes the GN Alertline, ethical decision-making, business conduct, employment practices, compliance with laws and regulations, conflict of interest, bribery, and third-party management.

The GN Ethics Guide is managed and updated by the Group Business Ethics & Compliance department and applies to all GN employees, including members of the Board of Directors. The EU Whistleblower Directive has been incorporated into Danish law and GN has established a whistleblower hotline, the GN Alertline, and implemented a Non-Retaliation Policy that ensures the protection of whistleblowers. The GN Alertline is a secure and confidential reporting tool hosted by an independent third party. This hotline is available to all employees and external stakeholders and can be accessed on the GN Group website via www.gn.com/whistleblower and for employees also via GN’s intranet. Concerns can be submitted verbally and in writing. The Group Business Ethics & Compliance department serves as GN’s designated investigation unit in compliance with the Danish whistleblower law.

GN’s Anti-Corruption Policy outlines expectations and requirements to prevent bribery and corruption. It also provides guidance for employees on how to report misconduct or seek clarification on concerns. The policy is communicated through internal awareness campaigns, e-learnings and in-person training sessions. The Policy defines the purpose, scope, ownership, and responsibilities related to the management of anti-corruption. The Policy explains key terminology related to anti-bribery and anti-corruption, among providing guidance on key processes to prevent and detect misconduct. Anti-corruption and anti-bribery training is mandatory for all employees incl. consultants on an annual basis. GN has not registered any convictions and fines related to violation of anti-corruption or anti-bribery laws.

GN’s Anti-Corruption Policy outlines expectations and requirements to prevent bribery and corruption. It also provides guidance for employees on how to report misconduct or seek clarification on concerns. The policy is communicated through internal awareness campaigns, e-learnings and in-person training sessions. The Policy defines the purpose, scope, ownership, and responsibilities related to the management of anti-corruption. The Policy explains key terminology related to anti-bribery and anti-corruption, among providing guidance on key processes to prevent and detect misconduct. Anti-corruption and anti-bribery training is mandatory for all employees incl. consultants on an annual basis. GN has not registered any convictions and fines related to violation of anti-corruption or anti-bribery laws.

The EU Whistleblower Directive has been incorporated into Danish law and GN has established a whistleblower hotline, the GN Alertline, and implemented a Non-Retaliation Policy that ensures the protection of whistleblowers. The GN Alertline is a secure and confidential reporting tool hosted by an independent third party. This hotline is available to all employees and external stakeholders and can be accessed on the GN Group website via www.gn.com/whistleblower and for employees also via GN’s intranet. Concerns can be submitted verbally and in writing. The Group Business Ethics & Compliance department serves as GN’s designated investigation unit in compliance with the Danish whistleblower law.

The EU Whistleblower Directive has been incorporated into Danish law and GN has established a whistleblower hotline, the GN Alertline, and implemented a Non-Retaliation Policy that ensures the protection of whistleblowers. The GN Alertline is a secure and confidential reporting tool hosted by an independent third party. This hotline is available to all employees and external stakeholders and can be accessed on the GN Group website via www.gn.com/whistleblower and for employees also via GN’s intranet. Concerns can be submitted verbally and in writing. The Group Business Ethics & Compliance department serves as GN’s designated investigation unit in compliance with the Danish whistleblower law.

The EU Whistleblower Directive has been incorporated into Danish law and GN has established a whistleblower hotline, the GN Alertline, and implemented a Non-Retaliation Policy that ensures the protection of whistleblowers. The GN Alertline is a secure and confidential reporting tool hosted by an independent third party. This hotline is available to all employees and external stakeholders and can be accessed on the GN Group website via www.gn.com/whistleblower and for employees also via GN’s intranet. Concerns can be submitted verbally and in writing. The Group Business Ethics & Compliance department serves as GN’s designated investigation unit in compliance with the Danish whistleblower law.

GN’s Anti-Corruption Policy outlines expectations and requirements to prevent bribery and corruption. It also provides guidance for employees on how to report misconduct or seek clarification on concerns. The policy is communicated through internal awareness campaigns, e-learnings and in-person training sessions. The Policy defines the purpose, scope, ownership, and responsibilities related to the management of anti-corruption. GN has appointed Group Business Ethics & Compliance department as the designated whistleblower investigation unit, in compliance with Danish law. Oversight of these investigations lies with GN’s Audit Committee, which is updated quarterly on findings and recommendations on cases received through the GN Alertline.

All employees and consultants are required to complete the annual mandatory Ethics Guide e-learning. In-person training is also offered where needed. Additionally, all new employees are asked to read and acknowledge the GN Ethics Guide as part of their onboarding.

GN’s Group Business Ethics & Compliance department regularly conducts onsite compliance reviews across all levels of GN, with a focus on anti-corruption and anti-bribery. The department also performs broader planned reviews in collaboration with Group Legal and Group Financial Reporting & Controlling.