Whistleblower Reporting Policy

All individuals who have an employment contract with DAF (or have had one in the past), and all individuals who perform (or have performed) work for DAF in any other capacity. External stakeholders of DAF, such as suppliers, applicants, partners, etc., can also make a report.

The policy can be used to report suspicions of potential wrongdoings or violations of (inter)national laws and regulations within or involving 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, public health, personal safety, or proper functioning of the company due to improper actions or omissions.

If you suspect or know that there may be misconduct and/or violations, you can report this to your contact person at DAF. If this reporting channel is not an option, you can use the PACCAR Ethics Line, where you can report anonymously if desired. You can also discuss your concerns confidentially with the Compliance Director of DAF before making a report. You can do this by contacting our Compliance Office via the contact form below

You can also request information, advice, and support regarding reporting a (suspected) misconduct or a violation of Union law (local and European laws and regulations) from the competent authority (see under 'How can you make a report').

If you choose to follow this reporting policy of DAF, you can make a report in writing or verbally to your contact person at DAF or to the Compliance Director via the below contact form. This can also be done anonymously if desired. If you want to make a completely anonymous report, you can use the PACCAR Ethics Line. More information about the PACCAR Ethics Line can be found under the section Frequently Asked Questions'/'FAQs on the PACCAR Ethics Line website.

When making a report of suspected wrongdoings, it should be done in good faith and supported by relevant information to the extent possible.

Instead of making a report at DAF, you can also report directly to the competent (external) authority if you suspect misconduct or a violation of Union law (local and European laws and regulations). Competent authorities include:

1. The Competition and Markets Authority (CMA);
2. The Financial Conduct Authority (FCA);
3. Information Commissioners Office (ICO);
4. The Bank of England (BoE);
5. The Medicines and Healthcare Products Regulatory Agency (MHRA);
6. Organizations and administrative bodies, or parts thereof, designated by general administrative order or ministerial regulation

Reporting directly to your contact person at DAF, to the Compliance Director, or via the PACCAR Ethics Line is preferred by DAF, as this allows the misconduct or violation to be addressed most quickly.

 

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

The Compliance Director, or a person appointed by them if necessary, will first assess the appropriate action to be taken and the need for any investigation based on the report. The Compliance Director will promptly, but no later than within seven days, send the reporter a confirmation of receipt of the report. The report will be registered by the Compliance Director in a designated register.

The Compliance Director will, as soon as reasonably possible, submit a proposal for an investigation to the Integrity Committee based on the report, unless:

• The report is not based on reasonable grounds, or
• It is clear in advance that the report does not concern a wrongdoing, suspicion of a wrongdoing, or a violation or risk of violation of (inter)national laws and regulations.

 

If the Integrity Committee decides not to initiate an investigation, the Compliance Director will inform the reporter within two weeks after submission of the report. This decision will be accompanied by reasons.

If the Integrity Committee decides to initiate an investigation, the Compliance Director will inform the reporter of this within two weeks of the submission of the report.

 

For the purpose of the investigation following a report, the Compliance Director has the authority to request all relevant documents and interview all relevant parties deemed necessary for the formation of their advice to the Integrity Committee.

If information is provided that must remain confidential due to its nature, it will be reported to the Compliance Director.

The Compliance Director may engage experts to obtain the required information.

As soon as possible after receiving the report, the Compliance Director will document the findings in an advice report addressed to the Integrity Committee. The advice report will describe the validity of the report and, if applicable, make recommendations.

The advice report with recommendations will be provided to the Integrity Committee, in anonymized form if necessary to protect the reporter, and while respecting the confidentiality 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 Board of Management will inform the reporter and any person the report concerns in writing of the Integrity Committee's position regarding the report. In exceptional cases, this period can be extended. The Compliance Director will inform the reporter in writing of any such extension, stating the reasons.

Reporters who make good faith reports of wrongdoings covered by this policy will not be intimidated or disadvantaged (prohibition of retaliation), nor will they face any other negative consequences (e.g., regarding their employment) for expressing their concerns. This prohibition of retaliation also applies to individuals who support the reporter and/or other involved third parties. 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 research, speaking, workplace, and/or contact bans on the reporter or the reporter's colleagues, in any form;
• Intimidating the reporter by threatening certain measures or actions if the report is pursued.

 

DAF does not tolerate any form of intimidation or retaliation and will take disciplinary measures against relevant colleagues or supervisors if necessary.

The prohibition of retaliation does not apply in cases of personal complaints, criticism of policy choices made, or objections of conscience. The prohibition of retaliation also does not apply if the reporter acts for personal gain or if false accusations are made intentionally, for improper reasons, or with malicious intent.

If a reporter believes they are being punished due to their position as a reporter of alleged wrongdoings or for participating in an investigation following a report, they are encouraged to immediately report this to the Compliance Office or the Compliance Director, so that appropriate measures can be taken by DAF.

If it is found that the reporter has been personally involved in alleged wrongdoings, making a report of the wrongdoings does not exempt the reporter from potential (disciplinary) measures by DAF or from civil, criminal, or legal liability. However, DAF will always consider the fact that a reporter voluntarily and in good faith reported their suspicions of wrongdoings in accordance with this policy.

During investigations, DAF will comply with applicable privacy and data protection laws and requirements, as outlined in its internal policies.