About ManpowerGroup

The whistleblower scheme should be regarded as a complement to direct and ongoing workplace communication concerning errors and unsatisfactory conditions, among other issues. Furthermore, this scheme also complements existing channels, such as contacting immediate superiors, HR Lead, or country management.

ManpowerGroup encourages the use of its whistleblowing scheme, which enables the prompt and effective internal handling of any violations. Nevertheless, the whistleblower retains the liberty of choosing between submitting a report to the company's whistleblowing scheme or an external whistleblowing scheme (the Danish Data Protection Agency or the National Whistleblower Scheme)

It is worth noting that the availability of ManpowerGroup's whistleblowing scheme does not preclude the option of reporting through external channels, such as regulatory authorities.

In ManpowerGroup, we have a local Compliance Officer and a Global Ethics and Compliance Team.

• Our local Danish Compliance Officer is:
  HR Lead, Charlotte Desvig-Nielsen, mobile +45 2778 0431, email charlotte.desvig-nielsen@manpowergroup.dk
  
  
• Our Global Ethics and Compliance Team:
  Phone +1 414 906 7024, email ethics.training@manpowergroup.com 

Reports to our whistleblower program are handled:

• Locally in Denmark by:
  HR Lead, Charlotte Desvig-Nielsen, mobile +45 2778 0431, email charlotte.desvig-nielsen@manpowergroup.dk
  
  
• Globally by:
  Global Ethics and Compliance Team, 100 Manpower Place, Milwaukee, WI 53212, USA.
  The team leader is: Richard Buchband – Senior Vice President, General Counsel, Secretary, and Chief Compliance Officer, phone +1 414 906 6618, email generalcounsel@manpowergroup.com

For individual report inquiries or questions about ManpowerGroup's whistleblower scheme, please contact:

Charlotte Desvig-Nielsen
HR Lead
Oldenburg Allé 3, 1. Tv, DK-2630 Taastrup
mobile: +45 2778 0431, Email: charlotte.desvig-nielsen@manpowergroup.dk

Whistleblower reports made to our local Danish Compliance Officer are conducted via regular email (Outlook), mobile, or in person.

Whistleblower reports to the Global Ethics and Compliance Team are made via external provider Navex Global (EthicsPoint and AT&T), which registers and forwards messages to the Global Ethics and Compliance Team for further processing.

Moreover, the processing of the report may require the assistance of an external party, such as Dansk Erhverv, legal counsel, or auditors, depending on the content and nature of the report.

ManpowerGroup's whistleblower scheme enables individuals to report information relating to serious violations or other serious matters that may not be directly linked to legal violations. Such reports can be made concerning incidents that have occurred or are anticipated to occur within the organization.

A legal violation or other matter will generally be considered serious if it is in the public interest to bring it to light.  However, trivial breaches or violations of insignificant provisions are not covered.

It is worth noting that whistleblowers' reports concerning their own employment relationship are generally not covered unless they involve sexual harassment or gross harassment.

Information about other matters, including violations of internal guidelines of a less serious nature, such as rules concerning sick leave, dress code, and information about other minor personnel-related conflicts, do not constitute serious violations and should not be reported to the program. Instead, such information should be directed to the immediate supervisor, HR lead, or country management following the relevant guidelines.

It is expected that individuals who use the whistleblower program do so in good faith and that the information they provide is accurate and reliable.

Attachment 1 provides examples of serious legal violations, serious matters, and information that are not covered by the whistleblower program.

Reporting to ManpowerGroup's whistleblower program:

• Local Danish Compliance Officer:
  • Mobile:
  • Email:
  • ManpowerGroup, Oldenburg Alle 3, 1. Tv, 2630 Taastrup
    
    
• Global Ethics and Compliance Team/ Ethics Hotline (available 24 hours, 7 days a week):
  • Dial toll-free via AT&T access code 8001 0010, wait for the dial tone, and then dial 800-210-3458.
  • Global website: Ethics (manpowergroup.com)
  • Danish website: Home (manpowergroup.dk)
  • Direct reporting: manpowergroup.ethicspoint.com
  • Mobile App: ManpowerGroup EthicsCompass

ManpowerGroup's whistleblower scheme is available to the following individuals:

• ManpowerGroup/Experis A/S employees, including temporary workers
• Suppliers, customers, and other partners, including consultants
• And the general public at large

ManpowerGroup's whistleblower unit will acknowledge receipt of a report within seven days, depending on the method of submission.

• Local Danish Compliance Officer:
  • Mobile +45 2778 0431 - Confirmation via SMS if the number is provided.
  • Email charlotte.desvig-nielsen@manpowergroup.dk - Confirmation via email if the email is provided.
  • Physical presence at Oldenburg Alle 3, 1. tv, 2630 Taastrup - Confirmation via email if the email is provided.

• Global Ethics Compliance Officer/ Ethics Hotline (available 24 hours, 7 days a week):
  • Email response via the system, both when reporting via a telephone hotline and if reporting through other systems.

ManpowerGroup's whistleblower unit will then carefully follow up on the report. The content and nature of the report determine the follow-up process. Upon receipt of a report, our whistleblower unit will conduct an initial assessment to determine whether the report falls within the scope of our whistleblower program. Reports that fall outside the scope of the program or are deemed clearly unfounded will be rejected. We will make every effort to notify the whistleblower of the rejection, if possible.

If the report falls within the scope of the law, it will be processed. This may involve ManpowerGroup's Whistleblower Unit gathering further information internally within the ManpowerGroup organization (locally or globally), depending on the content and nature of the report. Depending on the circumstances, it may also involve further dialogue with the whistleblower.

Follow-up examples

• Initiation of an internal investigation within the company.
• Notification to the company's top management, Nordic management, or other global leadership.
• Report to the police or relevant regulatory authority.
• Closure of the case due to lack of or insufficient evidence.

Within three months of confirming receipt of the report, the Whistleblower Unit will provide feedback to the whistleblower. This means that depending on the content and nature of the report, the Whistleblower Unit will inform the whistleblower about the measures that have been initiated or are being considered, and why the unit has chosen this follow-up action.

If it is not possible to provide feedback within the deadline, ManpowerGroup's Whistleblower Unit will inform the whistleblower accordingly and whether additional feedback can be expected. This may be due to, for example, the initiation of an internal investigation that cannot be concluded within the deadline.

Feedback must comply with applicable laws, including data protection laws (GDPR). This means, among other things, that there must be a legal basis for disclosing sensitive information. It depends on a specific assessment which information can be provided in the follow-up to the whistleblower.

Personnel affiliated with the Whistleblower Unit at ManpowerGroup are subject to a particular obligation of confidentiality regarding the data contained within the reports.

The obligation of confidentiality pertains exclusively to the information contained in the report. If a report leads to the initiation of a case, the further information gathered in this regard will not be subject to the duty of confidentiality.

The whistleblower unit of ManpowerGroup ensures that reports are handled with the utmost confidentiality.

Information from a report is processed following the processing rules in Section 22 of the Whistleblower Act and in the General Data Protection Regulation and the Data Protection Act. According to Section 22 of the Whistleblower Act, ManpowerGroup's Whistleblower Unit may process personal data, including sensitive information and information on criminal offenses, if necessary to process a report received in connection with ManpowerGroup's whistleblower scheme.

In certain instances, it may be necessary to disclose information obtained from a report, particularly for the purpose of conducting follow-up investigations. Prior to the disclosure of any information concerning the whistleblower's identity, the whistleblower will be duly notified, unless such notification is deemed to jeopardize an ongoing investigation or legal proceedings. This may occur if the disclosure of the whistleblower's identity is perceived to pose a risk of evidence being destroyed or concealed, witnesses being influenced, or if there is a suspicion that the whistleblower has submitted a report containing false information.

A whistleblower may not be subjected to reprisals, including threats of or attempts at reprisals, because they have made a report to ManpowerGroup's Whistleblower Unit or an external whistleblower scheme (Data Protection Agency, The National Whistleblower Scheme). Furthermore, the whistleblower may not be hindered or attempted to be hindered from making reports.

Reprisals are understood as any form of unfavorable treatment or consequences in response to an internal or external report, which causes or may cause harm to the whistleblower.

The whistleblower cannot be held liable for reporting confidential information if they have reasonable grounds to believe (in good faith) that the information in a report is necessary to expose a serious legal violation or a serious matter.

Attempts by ManpowerGroup's employees or management to prevent a whistleblower from making a report or to retaliate against a whistleblower who has reported in good faith will result in employment consequences.

The Ministry of Justice has prepared a guide for individuals who wish to submit or are considering submitting information as whistleblowers. The guide provides a comprehensive overview of whistleblower legislation, including descriptions of whistleblower schemes and reporting options, as well as the rights of whistleblowers and whistleblower protection. The guide can be accessed on the Ministry of Justice's website www.jm.dk – you may search for 'whistleblowing' to locate it.