1. This Policy is applicable within Rood Testhouse International N.V. (Rood N.V.) and its subsidiaries. This Policy was introduced to enable persons employed by one of the above-mentioned Companies to report any suspicions of non-compliance with (legal) regulations or policies, as specified below, without any prejudicial implications for these persons.
    
2. A suspicion of non-compliance must be based on reasonable grounds and involve an (impending) offence, an (impending) infringement of legislation or regulations, (impending) deliberate misinformation of public institutions, an infringement of the guidelines and by-laws applicable within the Company and/or (impending) deliberate withholding, destruction or manipulation of information regarding facts that fall within the scope of this document.
    
3. The Chairman of the Board of Rood N.V., or, as the case may be, the only Chairman of Rood N.V. in the event where Rood N.V. has a single Managing Director rather than a Board of Directors, is further referred to as “Chairman of the Board”.
    
4. This Policy shall be effective immediately.
    

Article 2 - Reporting to the Chairman of the Board

1. An employee may report suspected non-compliance to the Chairman of the Board. If the employee so wishes, this suspicion can also be reported to his/her direct line manager.
    
2. The Chairman of the Board sends a confirmation to the employee who reported the suspicion of non-compliance, including the date when the suspicion of non-compliance was reported to the Chairman of the Board.
    
3. The Chairman of the Board launches an investigation into the reported case of suspected non-compliance as soon as possible. The report of suspected non-compliance shall be treated as confidential. The name of the reporting employee (the whistle blower) shall not be revealed during the investigation and this employee’s anonymity shall be guaranteed as much as possible.
    

Article 3 - Reaction from the Chairman of the Board

1. Within six weeks of having reported the suspected non-compliance to the Chairman of the Board, the employee shall be informed in writing of the Chairman’s findings and point of view. If the report has resulted in direct action, the Chairman of the Board also indicates in this letter which action has been taken.
    
2. If the Chairman of the Board is unable to take a position within six weeks, the employee is informed of the estimated time required to assess the case and take a position.
    

Article 4 - Reporting to the Chairman of the Supervisory Board

1. If the suspicion of non-compliance (may) involve the Chairman of the Board, the employee should report this suspicion to the Chairman of the Supervisory Board of Rood N.V. An employee can also decide to report to the Chairman of the Supervisory Board if the employee has not received an assessment and position of the Chairman of the Board within the period as stipulated in Article 3, subs 1 and 2.
    
2. The Chairman of the Supervisory Board sends a confirmation to the employee who reported the suspicion of non-compliance, including the date when the suspicion of non-compliance was reported to the Chairman of the Supervisory Board.
    
3. The Chairman of the Supervisory Board launches an investigation into the reported case of suspected non-compliance as soon as possible. The report of suspected non-compliance shall be treated as confidential. The name of the reporting employee (the whistle blower) shall not be revealed during the investigation and this employee’s anonymity shall be guaranteed as much as possible.
    

Article 5 - Reaction from the Chairman of the Supervisory Board

1. Within six weeks of having reported the suspected non-compliance to the Chairman of the Supervisory Board, the employee shall be informed in writing of the Chairman’s findings and point of view. If the report has resulted in direct action, the Chairman of the Supervisory Board also indicates in this letter which action has been taken.
    
2. If the Chairman of the Supervisory Board is unable to take a position within six weeks, the employee is informed of the estimated time required to assess the case and take a position.
    

Article 6 - Legal protection

1. An employee who reported a suspicion of non-compliance, in good faith, in accordance with the stipulations of this Policy document and based on reasonable grounds, shall not suffer any negative implications regarding his/her position as a consequence of reporting the suspicion of non-compliance.