Reporting Response Plan

When you report a (suspected) violation, you will receive a confirmation of the receipt. A summary and handling proposal is sent to the Integrity Committee by the Director Compliance.

This is usually done within two weeks upon the receipt of the report. The Integrity Committee will assess the case and decide upon dismissal or investigation. This decision will be communicated to the reporter. If it is decided that the case will be investigated, the case is assigned to an investigator. The investigator performs an initial assessment of credibility, context and (potential) seriousness of the report.

If investigation is deemed required, the Integrity Committee will form an Investigation Team. Investigation is always required when the report:

- contains alleged violations of the FCPA or other applicable anti-corruption laws;
- contains alleged violations of anti-trust laws;
- involves PACCAR EU's top management; and/or
- could otherwise potentially have a major to massive reputational impact on DAF/PACCAR (hereafter the Company).
 
The Investigation Team should be independent and therefore not contain a direct colleague, subordinate or the supervisor of the suspect or reporter.

The Investigation Team will provide the Integrity Committee with preliminary information on the planning of the investigation. The primary role of the Investigation Team is to gather the information and documentation regarding the report (fact finding). It is up to the Integrity Committee to formulate an opinion on whether the suspected violation has occurred. 

After setting up the Investigation Team, the purpose and scope of the investigation shall be defined in the investigation plan, ideally within one week. At this point, and after assessing the credibility and context in which any report is made, the Investigation Team can advise the Integrity Committee to dismiss a report (e.g. due to little or no evidence to substantiate the alleged violation). In that case, the Investigation Team shall document and archive this advice. The decision of the Integrity Committee will be substantiated in communication to the reporter.

After planning the investigation, the following steps shall be completed as soon as possible:
- Securing evidence
- Conducting interviews
- Performing and verifying analysis
- Intermediate status reporting to Integrity Committee

The investigation should be done within 2 months after the receipt of the reporting. In specific circumstances the Integrity Committee can extend the investigation period, which will be communicated to the reporter.

Findings and observations shall be properly documented. And a final report shall be provide by the Investigation Team to the Integrity Committee. The Integrity Committee should limit the distribution and presentation of the Final Report on a need-to-know basis to authorized personnel only.

A summary of findings or the final result will be provided to the reporter by the Integrity Committee.

Depending on the findings of the investigation, the Integrity Committee will advise relevant line management in case of a Compliance related suspected violation or in case of any other type of suspected misconduct, on the appropriate course of action such as, but not limited to:

i. Declaring the report inadmissible / take no further measures.
ii. Taking disciplinary actions, e.g., written warning, compulsory training, suspension, reduction in pay, demotion, or termination of employment for the employees(s) involved.
Any such disciplinary action will properly reflect the severity of the misconduct.
iii. Developing additional measures, such as training, strengthening of internal controls, creation of additional policies or other measures that aim to promote a culture of integrity and compliance.