Whistleblower Policy

All individuals who have (or have had) an employment contract with DAF and all individuals who otherwise perform (or have performed) work for DAF can file a report. External stakeholders of DAF, such as suppliers, applicants, business partners, etc., can also file a report.

The policy can be used to report suspicions of possible wrongdoings or violations of (inter)national laws and regulations within or by DAF. Examples include:

• (Possible) Criminal offenses or violations of (inter)national laws and regulations;
• Violations of the PACCAR Code of Conduct, PACCAR Standard Policies, compliance rules, or other internal policies of DAF/PACCAR; or
• Threats to the environment, risks to public health, risks to personal safety, or risks to the proper functioning of the company due to improper actions or omissions.

If you suspect or know of possible wrongdoings and/or violations, you can report it to your regular DAF contact person. If that reporting channel is not an option, you can use the PACCAR Ethics Hotline, where you can file an anonymous report if desired. You can also discuss your concerns confidentially with the Compliance Director before filing a report. Contact can be established via our Compliance Office by using the below contact form.

You can also request information, advice and support regarding suspected wrongdoings or violations of Union law (local and European laws and regulations) from the Whistleblowers Authority or other authorities (see Dutch examples in the ‘How you can file a report’ section) in your country (if applicable).

If you choose to follow DAF's reporting policy, you can file a written or oral report to your regular DAF contact person. This can also be done anonymously if desired. If you want to file a completely anonymous report, you can use the PACCAR Ethics Hotline. More information about the PACCAR Ethics Hotline can be found on the PACCAR Ethics Hotline website under FAQs.

When filing a report of suspicions of possible wrongdoings, it must be done in good faith and supported, as far as possible, by relevant information.

Instead of making a report via DAF’s procedure, you can also make a report directly to the competent (external) authority regarding suspicions of wrongdoings or violations of Union law (local and European laws and regulations). Competent authorities include (country specific, here Dutch Authorities):

• The Authority for Consumers and Markets (ACM);
• The Netherlands Authority for Financial Markets (AFM);
• The Dutch Data Protection Authority (AP);
• The Dutch Central Bank (DNB);
• The Whistleblower Authority;
• The Healthcare and Youth Inspectorate (IGZ);
• The Dutch Healthcare Authority (NZ);
• The Authority for Nuclear Safety and Radiation Protection (ANVS); and
• Organizations and administrative bodies or parts thereof designated by general administrative order or ministerial regulation.

Reporting via DAF’s procedure is preferred by us because it allows the suspected wrongdoing or violation to be addressed more quickly, and if reported externally, DAF misses the opportunity for internal investigation.

Once a report is received, it is forwarded to the Compliance Director. DAF must treat the report confidentially. All individuals involved in handling a report must not disclose the identity of the reporter or other involved parties without the explicit written consent of the reporter, and must treat the information about the report confidentially.

The Compliance Director, or a person designated by him/her if necessary, first assesses what action needs to be taken and what investigation (if necessary) needs to be conducted based on the report. The Compliance Director promptly, but no later than within seven days, sends a confirmation of receipt of the report to the reporter. The Compliance Director registers the report in a dedicated register.

The Compliance Director ensures that the report is documented in writing and presents this documentation to the reporter for confirmation and signature. The reporter receives a copy of this documentation.

The Compliance Director submits a proposal for an investigation to the Integrity Committee as soon as reasonably possible following the report, unless:

a) The report is not based on reasonable grounds, or

b) It is clear in advance that the report does not concern a wrongdoing, suspicion of wrongdoing, or violation or risk of violation of (inter)national laws and regulations.

If the Integrity Committee decides not to conduct an investigation, the Compliance Director informs the reporter within two weeks after the report is submitted. This decision is substantiated.

If the Integrity Committee decides to conduct an investigation, the Compliance Director informs the reporter about this within two weeks after the report is submitted.

For the purposes of the investigation following a report, the Compliance Director is authorized to request all relevant internal documents and interview all relevant parties that he/she deems necessary for formulating his/her advice to the Integrity Committee.

If information is provided that must remain confidential due to its confidential nature, this is reported to the Compliance Director. The Compliance Director may engage experts to obtain the necessary information.

The costs associated with this are submitted to the Integrity Committee for approval before engagement.

As soon as possible after receiving the report, the Compliance Director documents his/her findings in an advice report addressed to the Integrity Committee. The advice report describes the validity of the report and may include recommendations.

The advice report with recommendations is provided to the Integrity Committee in an anonymized form, if necessary, to protect the reporter and in accordance with the confidential nature of the information provided to the Compliance Director.

Within a maximum of three months after receiving the report, the Compliance Director or a member of the management informs the reporter and any person concerned by the report in writing of the Integrity Committee's substantive position regarding the report. In exceptional cases, this period may be extended. The Compliance Director reports this in writing to the reporter with reasons.

Reporters who file reports of wrongdoings covered by this policy in good faith will not be intimidated or disadvantaged (non-retaliation policy) or face any other negative consequences for expressing their concerns.

This non-retaliation policy also applies to anyone assisting the reporter and/or any other involved third party. Retaliation includes, but is not limited to:

• Bullying, ignoring, and excluding the reporter;
• Making unfounded or disproportionate accusations regarding the performance of the reporter;
• Imposing actual investigative, speaking, workplace, and/or contact bans on the reporter or colleagues of the reporter, in any form or wording;
• Intimidating the reporter by threatening certain measures or behaviors if the report is pursued.

DAF does not tolerate any form of intimidation or retaliation and will take disciplinary measures against the relevant colleagues or managers if necessary. The non-retaliation policy does not apply in cases of personal complaints, criticism of policy choices, or conscientious objections. The non-retaliation policy also does not apply if the reporter acts for personal gain or makes false accusations that were made knowingly, for improper reasons, or with malicious intent.

If a reporter believes they are being punished because of their position as a reporter of alleged wrongdoings or because they participate in an investigation following a report, they are encouraged to immediately report this to the Compliance Director, so that DAF can take appropriate measures.

If it turns out that the reporter was personally involved in alleged wrongdoings, making a report does not exempt the reporter from possible measures by DAF or from civil, criminal, or legal liability. However, DAF will always take into account the fact that a reporter voluntarily and in good faith reported their suspicions of wrongdoings in accordance with this policy. DAF will comply with applicable privacy and data protection laws and requirements during investigations, as set out in its privacy statement.