Employees and other complainants who believe they are aware of a violation of the Code of Conduct or any individual HA Group policy are encoura ged to report their concern, complaint, report or inquiry. Complainants have many ways in which they can report a concern or incident related to this Code of Conduct. 

As an additional communication tool for specific types of situations HA Group has established an anonymous reporting tool (also known as “whistleblower hotline”) through which employees can confidentially and anonymously report perceived violations of this Code of Conduct. This hotline is not a substitute for routine communications within our organization between employees and their supervisors and managers, particularly as to workplace du ties. Hence, regular business matters that do not require anonymity should be directed to the employee’s supervisor and should not be submitted using this service. Rather, this whistleblower hotline is an additional communication tool for specific types of situations and it is provided because we believe that it is a good business practice to do so.