Whistleblower Channel

■ Introduction

This Whistleblower policy is prepared in compliance with the Finnish Act (2022:1171) on the protection of persons reporting breaches of European Union and National law (hereinafter "the Act").

Huawei Technologies Oy (Finland) Co. Ltd (hereinafter "Huawei Finland") is committed to preventing and combatting bribery, corruption and other misconduct in our company. The purpose of this Whistleblower Policy is to ensure that potential misconduct in a work-related context can be reported in a confidential manner by using a whistleblower channel according to the Act. The policy shall further ensure that reporting persons are protected from any retaliation in response to such reporting according to the Act.

The whistleblower channel is intended to complement, but not replace, other reporting channels, such as reporting to your immediate manager, your manager's manager, HR, or by using the group reporting channel at BCGcomplain@huawei.com.

■ Who can report?

The whistleblower channel can be used by anyone at Huawei Finland, including but not limited to shareholders, board members, executives, managers, officers, directors, employees, consultants, contractors, trainees, interns, former employees, job seekers who have attended job interview(s), volunteers, suppliers etc.

■ How can a report be submitted?

A report can be submitted through the whistleblower channel in two (2) different ways:
• In writing: A written report can be submitted by sending an email to Whistle4HWFI@huawei.com
• At a voluntary physical meeting after having submitted a written report by email: Upon request, reporting can take place at a physical meeting, where more information of the case is collected. Please inform in your email if you wish to share more information in a physical meeting. Please also note that complete anonymity cannot be guaranteed in a physical meeting although your information will be only shared to parties required to carry out the investigation.

You also have the possibility to report externally to competent authorities. For more information and links to the competent authorities see: https://oikeuskansleri.fi/en/centralised-external-reporting-channel. Please note that Office of the Chancellor of Justice has been given the task to handle reports that are not covered by any other competent authority’s area of responsibility.

■ Is it possible to remain anonymous?

You can choose to remain anonymous when reporting (you may e.g. use an anonymous email address). However, in cases where you cannot be reached again, kindly note that Huawei can only investigate as far as how much information is provided. Vague or incomplete information might be insufficient for initiating or completing a proper investigation. It is also welcomed if you would like to identify yourself when reporting. If you choose to identify yourself, it would be easier for us to quickly initiate a confidential dialogue with you, which may facilitate the investigation of your report. Whether you choose to remain anonymous or not, we will keep your identity strictly confidential. Reports will only be handled by designated personnel at Huawei Finland (see Section 9 below).

Please note that you are responsible for ensuring that your report is anonymous. For instance, if you send a report intended to be anonymous from your personal email address that contains your first and last name, Huawei cannot reasonably know that it is intended to be anonymous. Thus, Huawei responding to such an email asking for further information in accordance with this policy cannot be constituted as a violation of your right to anonymity as set out in this policy.

■ What kind of misconduct can be reported?

In accordance with Chapter 1, Article 2 of the Act (scope of the Act), you can report misconduct within Huawei Finland that you have become aware of in a work-related context. The misconduct may be ongoing or imminent and may consist of an act or omission. Examples of misconduct that can be reported are misconduct concerning but not limited to:

• accounting, internal accounting control, auditing, bribery, money laundering or other financial crime;
• public procurement, anti-trust and competition, product safety, transport safety, environmental protection, consumer protection, protection of privacy and personal data, security of network and information systems; and
• other misconduct that constitutes a violation of law or concerns the life and health of individuals.

You shall, to the best of your knowledge, ensure that the information included in the report is as truthful and complete as possible.

■ What kind of misconduct cannot be reported?

It should be in the public interest to disclose the reported misconduct. Any misconduct relating only to your work situation or your terms of employment should therefore, as a general rule, be raised through Huawei Finland’s other channels, for example by reporting to your immediate manager or your manager's manager or to HR.

■ Who can be reported

There are no restrictions regarding which individuals your report may concern. However, we ask you to keep in mind that your report should fulfil the requirements stated in Section 5 above.

Your identity will be kept strictly confidential in relation to the person whom the report relates to.

■ Confirmation and feedback

You will receive a confirmation that the report has been received within 7 days and feedback on the actions taken in response to the report within 3 months after confirmation of receipt. This correspondence will be sent to the email address from which you have reached out to Huawei Finland.

■ Handling of the report

The report will be handled in accordance with the Act as well as Huawei Finland's internal policies and procedures. Reports will be received by the HR department. Further investigation of a reported misconduct will be conducted by Huawei Finland’s Investigation Team consisting of the members from the HR, Compliance, Quality and Operations, and Legal Departments. If a report concerns an individual in the Investigation Team, the report will not be handled by that specific individual.

The investigation will take place as quickly as possible and in a confidential, fair and impartial manner.

If a report is investigated further, and if it is deemed strictly necessary, information in the report may be shared with other persons, within or outside Finland, in order to investigate the report or report the misconduct to the police. In such case, only the persons who have a direct link to the reported case will be contacted, and only for the sake of investigation.

Reports are stored and deleted in accordance with the requirements under the Act and applicable data protection legislation, including the General Data Protection Regulation (2016/679).

■ Prohibition against retaliation

You are protected from retaliation and other counter actions regardless of the outcome of the investigation, but the protective measures may not be applicable in relation to matters outside of the scope of the Act.

The prohibition against retaliation also applies in relation to persons who, in a work-related context, assist you in reporting (e.g. safety representatives) or in other ways are connected to you (e.g. colleagues and relatives), as well as in relation to legal entities (e.g. companies) that you own or work for.

■ Cooperation

You may be required to cooperate and provide information that is requested in connection with (i) internal investigations and (ii) inquiries and investigations by the police, a court, or a public authority. You shall, to the best of knowledge, ensure that all information provided is truthful.

■ Processing of personal data

The whistleblower channel involves the processing of personal data, which is used to investigate reported misconduct. Personal data is handled in accordance with applicable data protection legislation. For more information please read the Privacy Statement for Whistleblower Reporting.