As an internationally operating parcel service provider GLS Group stands for fair competition, integrity and responsibility.

Whistleblowing Procedure

At GLS, we adhere to clear ethical principles.

Adhering to clear ethical principles is an important pillar of our company's success. All our employees and collaborators are responsible for ensuring that we comply with the principles we have adopted. The improper actions of even a few individuals can undermine the good reputation of the entire company. Therefore, it is crucial to identify possible legal violations by our employees, collaborators, suppliers, or other third parties at an early stage, so that we can react quickly and address the situation effectively.

Whistleblower Protection Act - What Should Be Reported?

As of September 25, 2024, the Polish Whistleblower Protection Act of June 14, 2024, will be in effect. It requires us to establish and maintain an internal procedure for reporting legal violations and taking follow-up actions, referred to as the "internal reporting procedure." Whistleblowers, within the scope of making an internal report, can inform us about possible violations they have become aware of during their professional activity. Internal reports can be made in the following matters:

• Information about the suspicion of a criminal offense.

• Information about violations of the GLS Code of Business Standards.

• Information about violations of the law as defined in Article 3(1) items 1) - 17) of the Whistleblower Protection Act, i.e., actions or omissions that are illegal or intended to circumvent the law, related to:

1) Corruption;

2) Public procurement;

3) Services, products, and financial markets;

4) Anti-money laundering and counter-terrorism financing;

5) Product safety and compliance with requirements;

6) Transport safety;

7) Environmental protection;

8) Radiological protection and nuclear safety;

9) Food and feed safety;

10) Animal health and welfare;

11) Public health;

12) Consumer protection;

13) Privacy and personal data protection;

14) Security of networks and information systems;

15) Financial interests of the Treasury of the Republic of Poland, local government units, and the European Union;

16) The internal market of the European Union, including public law competition rules, state aid, and corporate taxation;

17) Constitutional freedoms and human rights in relations between individuals and public authorities, unrelated to the fields mentioned in items 1-16.

Reports regarding the violations mentioned above are covered by strict confidentiality to ensure maximum protection for whistleblowers and those mentioned in the reports. Whistleblowers are also legally protected from retaliation and any kind of reprisal.

Internal Organizational Unit Authorized to Accept Reports

The internal organizational unit within the GLS Poland structure authorized to receive internal reports is the GLS Poland Compliance Department.

Please note that you are protected as a whistleblower only if, at the time of reporting, you had reasonable grounds to believe that the information being reported was true and that it concerned a legal violation. You do not benefit from the protection provided to whistleblowers if you knowingly make a false report.

You can contact the internal unit of GLS Poland via:

1) GLS Integrityline - Report a Violation

or

2) Through our Ombudsman, Dr. Rainer Buchert:

Lawyer Dr. Rainer Buchert

Kaiserstraße 22

60311 Frankfurt am Main

Germany

Tel: +49 69 710 33 330 or +49 6105 92 1355

Fax: +49 69 710 34 444

E-mail: kanzlei@dr-buchert.de

Contact Form

Dr. Buchert will not handle complaints regarding non-criminal or similarly serious matters. In case of doubt, he will provide advice on how to proceed with the matter.

All reports will be handled with respect for anonymity. The contact person (lawyer Dr. Buchert) is bound by professional secrecy, which prohibits disclosing the identity of those who contact him without their explicit consent. He also has the right to refuse to provide evidence (including the identity of the reporter), even if requested by a court. Complaints submitted to the Ombudsman/lawyer will only be forwarded to the GLS Group after receiving consent from the person reporting.

External Entity Authorized to Accept Internal Reports

The external entity authorized by GLS Poland to accept internal reports is WKB Wierciński, Kwieciński, Baehr sp. k.

All employees, business partners, and third parties can contact them regarding the above matters:

WKB Wierciński, Kwieciński, Baehr sp. k.

Plac Małachowskiego 2, 00-066 Warsaw

Paderewskiego 7, 61-770 Poznań

Tel.: 22 201 00 95 (Mon-Fri, 8:00 AM - 8:00 PM)

E-mail: gls_zgloszenia@wkb.pl

When accepting reports, WKB acts with due diligence in accordance with the law and professional ethics.

WKB ensures the confidentiality of the data and identity of the reporters and any third parties mentioned in the report. WKB representatives are obligated to maintain professional secrecy, and therefore, keep all matters and information obtained during cooperation with GLS Poland confidential, except when WKB uses such information to properly perform their duties or when required by law.

Of course, doubts regarding the above matters can also be reported to the employee's direct supervisor or other contact persons within the GLS Group.

Contact for the GLS Poland Compliance Officer:

E-mail: compliance@gls-poland.com