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Integrity policy

Our ethics and integrity policy is based on the code of conduct and a series of protocols. Unica recognises the importance of ethical and honest behaviour on the part of its employees and for that reason works hard to promote general awareness of these issues. In 2023, we developed e-learnings in the field of ‘hard’ compliance including bribery, corruption and competition law, and ‘soft’ compliance focused on social safety.

At the introduction days for all new employees we discuss such issues as integrity, accepting gifts, forgery of documents and desirable behaviour. At management level we discuss these issues each quarter, and work to improve awareness on the ‘soft’ side. For example shouting and the impact of raised voices on employees. Integrity issues are also discussed in the Executive Committee (ExCo) and with the Supervisory Board.

A number of major amendments have been implemented in the new Whistleblowers Protection Act which came into force in February 2023. These changes have been included in the updated abuse rules. One important new aspect is the obligation to make it possible to submit reports anonymously. Starting in 2024, Unica complied with this requirement by implementing the new reporting system ‘ComplyLog’. Anyone who submits a report in this system receives a code (token) that enables them to monitor the progress of the report. Reports and correspondence can take place fully anonymously, via the system.

Both the external confidential advisors and the compliance officer provide our management, the Supervisory Board and the Joint Works Council with an annual report. Additional measures can then be formulated based on the outcome of these reports.