De Well Whistleblower & Ethics Reporting Policy
(Last Updated September 10, 2025)
Who May Report?
The Ethics Helpline is available to:
- De Well employees
- Third-party vendors and business partners
- Clients and members of the public who interact with De Well
What May Be Reported?
Concerns may include (but are not limited to):
- Discrimination, harassment, or workplace violence
- Conflicts of interest or misuse of company resources
- Bribery, fraud, theft, or falsification of records
- Breaches of confidentiality or data protection rules
- Insider trading or violations of export controls
- Any other suspected unethical, illegal, or non-compliant activity
How to Report
- Ethics Helpline (Confidential): anti-fraud@dewell.com
- Compliance Channel: compliance@dewell.com
Reports may be submitted anonymously
Handling of Reports
All reports are acknowledged and investigated promptly. Investigations are generally completed within 30 business days. If a delay occurs, you will be informed with an updated timeline. Only authorized personnel will access reports, and confidentiality will be maintained at all times.
Protection Against Retaliation
De Well strictly prohibits retaliation against anyone who raises a concern in good faith.
Commitment
By speaking up, you play an essential role in protecting our people, partners, and reputation.