Whistleblower Policy

Patria Group is committed to conducting business in compliance with all relevant legislative frameworks, including the EU Whistleblower Directive (EU 2019/1937) and applicable national implementation laws.
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The Whistleblower Policy (hereafter “Policy” or “WB Policy”) provides a robust, group-wide framework for reporting and addressing suspected Wrongdoing across Patria Oyj and its affiliated companies. The Policy reflects Patria's core values: integrity, transparency, and the protection of individuals who report misconduct in good faith.

The Whistleblower Policy aims to encourage employees and stakeholders to report any form of wrongdoing, thereby enabling Patria and ILIAS Solutions to prevent, detect, and address potential breaches efficiently.

The Policy’s scope covers not only legal breaches but also violations of Patria’s Code of Conduct, forming an essential part of the group’s Compliance Management System.

• Whistleblowing Channel: People Intouch’s SpeakUp platform, which guarantees secure reporting and investigation.
• Channel Manager: KPMG Finland’s Forensic Services, acting as the independent external manager of the Channel.
• Whistleblower: Any individual reporting a Wrongdoing in good faith through the Whistleblowing Channel. Protection is granted under the Whistleblower Act and EU Directive.
• Wrongdoing: any act that is in violation of Patria’s Code of Conduct.
• Report: Written or verbal submission of suspected Wrongdoing via the Whistleblowing Channel.
• Triage: The assessment of a Report for further action, categorization, and prioritization.
• Whistleblowing Management review: several decision-making levels ensure independent and impartial review, with the external channel manager escalating cases as required.

The Policy is inclusive, covering a range of stakeholders:

• Patria and ILIAS Solutions employees, trainees, and volunteers
• Jobseekers and previous employees
• Board members, managing directors, and shareholders
• Individuals under the direction of Patria’s and ILIAS Solutions contractors, subcontractors, and suppliers
• Self-employed persons

Reports must be based on honestly held suspicions or knowledge — rumors are not actionable under the Policy.

Reporting in good faith grants whistleblowers protection from retaliation, including discharge, demotion, or discrimination.
This protection extends under both Finnish and U.S. federal laws (41 USC 4712 / 10 USC 4701) for individuals disclosing evidence of gross mismanagement, waste of government funds, abuse of authority, or violation of law related to U.S. contracts or grants.

• Web: https://patria.speakup.report/en-GB/patria/home
• Mobile App/Phone: Use Patria’s enterprise-specific access code 105172 for secure submission.
• QR Code: Available for SpeakUp mobile application users.
• Reports can be anonymous; no metadata or IP addresses are stored by the Channel Manager. Whistleblowers should note the eight-digit case ID for follow-up.

Whistleblowers are encouraged to provide detailed information and regularly check the status of their report. Push notifications are available through the SpeakUp app.

• All reports are confidentially handled by the Channel Manager
• Access to reports is strictly limited and traceable; only assigned individuals may view or amend data.
• Reports are assessed (triaged) and assigned to the appropriate decision-making level, ensuring independence and resolving conflicts of interest.
• Whistleblowers receive acknowledgment of their report within 7 days and feedback or updates within 3 months.
• Possible actions include process improvement, internal investigations, or referral to supervisory authorities.
• Suspected individuals are guaranteed fair and due process throughout investigations.

• Belgium: Flemish, French, English, Phone: +32 80089326
• Finland: Finnish, English, Swedish, Phone: +358 800392912
• Germany: German, English, Phone: +49 8001818952
• Latvia: Dutch, English, Phone: +371 80005929
• Netherlands: Dutch, English, Phone: +31 107007503
• Sweden: Swedish, English, Phone: +46 201604703
• Call the local number, enter access code 105172, and follow instructions to leave a message or check the case status.
• Web submissions and follow-ups are available 24/7 at https://patria.speakup.report/en-GB/patria/home.

The Whistleblower Policy demonstrates the organization’s unwavering commitment to integrity, accountability, and the protection of individuals who courageously report suspected Wrongdoing.
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By empowering all stakeholders to raise concerns safely and confidentially, the Policy fosters a culture of transparency and trust at every level of Patria Group’s operations.