Whistleblower Mechanism

1. Applicability and Scope

This mechanism applies to all brands owned and operated by Wheat A/S, Wheat Kids Clothing UK Ltd, Wheat Fashion Ltd, Wheat Norge AS

Each entity is responsible for implementing this mechanism in accordance with applicable national legislation and regulatory requirements.

This mechanism is open to any external stakeholder, including suppliers, business partners, customers, NGOs, or other third parties, as well as any individual or group who may be adversely affected by Wheat A/S' operations, products, or business relationships.

2. Purpose

Wheat A/S is committed to conducting business responsibly and transparently across our value chain.

This mechanism establishes a secure and fair process for external stakeholders to raise concerns related to potential or actual adverse impacts linked to Wheat A/S' operations, products, or supply chain.

3. Scope of Grievances

This mechanism applies to grievances concerning:

  • Violations of applicable law or regulations
  • Human rights, labour rights, or workplace safety breaches in our supply chain
  • Environmental harm linked to Wheat A/S' operations or suppliers
  • Corruption, bribery, fraud, or unethical business practices
  • Misrepresentation of certifications, product claims, or ESG commitments

4. Submission of Grievances

External stakeholders may submit grievances through the following channels:

Online form (confidential):

Email:

Written submission: Wheat A/S Attn. Whistleblower Committee Grusbakken 12 2820 Gentofte, Denmark

5. Accessibility

This mechanism is publicly available via Wheat A/S' brand websites.

Where appropriate, Wheat A/S will seek to ensure that affected stakeholders are informed of the availability of this mechanism through supplier communication, contractual requirements, or onboarding processes.

6. Grievance Handling Process

6.1 Confidentiality and Fair Process

  • All grievances will be handled with strict confidentiality
  • Identities of complainants will not be disclosed without consent, unless legally required
  • Anonymous submissions will be accepted
  • Grievances will be reviewed objectively and without bias

6.2 Investigation and Resolution

  • Relevant Wheat departments (e.g. Compliance, ESG, Sourcing) will be involved in the investigation
  • Where the grievance concerns a supplier, the supplier may be contacted and asked to provide evidence or corrective actions
  • A corrective action plan may be developed where required

6.3 Remedy

Where Wheat A/S has caused or contributed to adverse impacts, we are committed to providing for or cooperating in their remediation.

Where impacts are directly linked to our business relationships, we will use our leverage to seek to prevent or mitigate the impact and enable access to remedy where appropriate.

6.4 Communication of Outcomes

The complainant will be informed of the outcome, to the extent possible without breaching confidentiality or legal obligations.

In cases involving systemic issues, aggregated findings may be disclosed in ESG reporting.

7. Process Timeline

Wheat A/S will:

  • Acknowledge receipt of a grievance within ten (10) working days
  • Assess the admissibility of the grievance
  • Inform the complainant of next steps and expected process timelines where contact information is available
  • Monitor implementation of agreed corrective actions where applicable

8. Recording and Data Management

  • All grievances will be logged in Wheat A/S' secure grievance system
  • Records will include the nature of the grievance, findings, actions taken, and outcomes
  • Data will be anonymized where appropriate and retained in line with GDPR and Wheat A/S' data protection policy
  • Aggregated data will be reviewed annually to identify trends and inform ESG risk management

9. Whistleblower Protection

External whistleblowers acting in good faith will not face retaliation, legal threats, or blacklisting from Wheat A/S.

This mechanism does not replace access to judicial or administrative remedies and may be used in parallel with other legal complaint procedures.

10. Responsibilities

  • Whistleblower Committee: Receives, records, and ensures impartial handling of grievances
  • Relevant Departments (e.g. Compliance, ESG, Sourcing): Conduct investigations and implement corrective measures
  • Management and Board: Provide oversight and ensure grievances are addressed at the appropriate level

11. Review of the Mechanism

This mechanism is reviewed annually to ensure compliance with applicable laws (including the EU Whistleblower Directive) and alignment with best practices in responsible business conduct.