Whistleblower Policy

Introduction
Sophie Bille Brahe (SBB) is committed to conduct business with integrity and to ensure that we live up to our standards and address any breaches that may happen through our organisation. We want to promote an open organisational culture, where it is safe to report serious offenses or suspicion of serious irregularities. We strive to identify all potential issues that need to be addressed and all reports of possible misconduct are taken seriously, and the matter investigated confidentially. 

This policy applies only to serious concerns, such as suspected or known breaches of law, violations of company policies, or other forms of misconduct related to Sophie Bille Brahe. It sets out how SBB will support anyone who wishes to report such matters, who to contact, and which reporting channels to use. It also explains the protections available to those making a report.

SBB encourages the use of the whistleblower scheme for any possible violations. The whistleblower is free to report through the Data Protection Authority's general, external whistleblower scheme: https://whistleblower.dk/ instead of the SBB’s scheme.

For general concerns, complaints, or feedback not related to misconduct, please refer instead to our Grievance Procedure, which provides a separate process for addressing everyday issues.


Purpose of this policy
The purpose of the whistleblower scheme is to ensure openness and transparency in relation to possible violations and serious irregularities.  

The purpose is:

- To prevent and investigate any suspected illegal actions and any clear and serious violations of internal guidelines or policies of SBB.

- To provide the opportunity for SBB employees, suppliers and business partners and other stakeholders to speak out about impermissible circumstances in the SBB without a fear of negative consequences.

- To provide a formal and secure procedure for protecting stakeholders that choose to come forward under the Whistleblower Policy.

- To protect the persons who report information through the whistleblower scheme.



Scope of this policy
The SBB whistleblower scheme can only be used to report serious offenses or suspicion of serious offenses of importance to the SBB’s performance and interactions.

Examples of Reportable Conduct includes violation for all human rights but are not limited to:

- Illegal conduct, such as theft, violence or threatened violence, and criminal damage against property, fraud, money laundering or misappropriation of funds.

- Offering or accepting a bribe.

- Financial irregularities.

- Failure to comply with, or breach of, legal or regulatory requirements.

- Criminal activity or violation of any applicable law or regulation.

- Theft or fraud against or by SBB including falsification of contracts, reports, or records.

- Purposeful misinformation or false statements.

- Inappropriate accounting practices, internal accounting controls or audit matters.

- Abuse of authority, including instructions not to report breaches to higher management or to the Ethic & Compliance Committee.

- Child labour forced labour and other violations of fundamental human rights.

- Significant adverse environmental impact.

- Sexual harassment.

- Serious harassment, e.g., on grounds of race, sex, colour, national or social origin, political or religious affiliation.

It is not intended for general concerns, complaints, or feedback. Those matters should instead be raised through our Grievance Procedure, which provides a separate process.



Reporting of breaches
All whistleblowing reports should be made through our Whistleblower Form Sophie Bille Brahe | Whistleblower Form. This channel is designed to ensure confidentiality and allow for anonymous reporting if preferred.


Processing of reports
Reports submitted through the Whistleblower Scheme are first received and screened by the SBB Whistleblower Unit. This initial review ensures that the report is not clearly unfounded or outside the scope of this policy. If the report is eligible for processing, it will be forwarded to the CEO and the Chair of the Board of Directors of Sophie Bille Brahe ApS.

All reports will be assessed and may be subject to investigation. While circumstances may require different approaches, all investigations will:

- Be handled confidentially and independently of those involved.
- Follow a fair process, ensuring equal treatment of all parties.
- Be conducted as quickly and efficiently as possible.
- Respect the presumption of innocence until an outcome is reached.
- Aim to establish whether there is sufficient evidence to substantiate the matters reported.

Confidentiality and protection
Whistleblowers are protected from reprisals, threats, or attempts to obstruct reporting. No one will suffer negative consequences for making a report in good faith through the SBB Whistleblower Scheme or an external whistleblower scheme (e.g., the Danish Data Protection Authority).

Members of the Whistleblower Unit have a strict duty of confidentiality regarding information received in reports.

This obligation applies only to information contained in the report itself. If a report leads to further proceedings, information collected during those proceedings is not covered by this obligation.



Retention of data
Information submitted under the Whistleblower Policy will be retained only for as long as necessary to comply with regulations and to process the case. If a report is dismissed as unfounded or outside the scope of the policy, the information will be deleted.

For any questions about the whistleblower process, please find all relevant contact information below:

Internal audit team whistleblower@sophiebillebrahe.com
ESG team esg@sophiebillebrahe.com


This policy is adopted in Copenhagen on 30^th September 2025.

The Whistleblower Policy is annually reviewed to ensure that Sophie Bille Brahe ApS is aligned with current good practices.