Introduction

Sensys Gatso, its subsidiaries and affiliates are committed to the highest possible standards of openness, honesty and accountability. In line with that commitment, we expect employees and others that we deal with who have serious concerns about any aspect of the company’s work to come forward and voice those concerns.

1. What is whistle blowing?
Employees are usually the first to know when something is going seriously wrong. A culture of turning a "blind eye" to such problems means that the alarm is not sounded and those in charge do not get the chance to take action before real damage is done. Whistle blowing can therefore be described as attracting management’s attention to information about potentially illegal and/or underhand practices, i.e. wrongdoing.

2. What is wrongdoing?
Wrongdoing involves any unlawful or illegal behaviour and may include the following:
-An unlawful act, whether civil or criminal
-Breach of the Sensys Gatso Code of Conduct
-Breach of or failure to implement or comply with any Sensys Gatso policy
-Unprofessional conduct not complying with established standards of practice
-Questionable accounting or auditing practices
-Practices likely to cause physical harm or damage to a person or to property
-Abuse of power or authority for any unauthorised or ulterior purpose
-Unfair discrimination in the course of the employment or provision of services
-Conflicts of interest

3. Who is protected?
Any individual making a disclosure or raises a concern under this Policy will be protected
if the individual:
-Discloses the information in good faith
-Believes it to be substantially true
-Does not act maliciously nor makes false allegations
-Does not seek any personal or financial gain

4. Who should you contact?
In order to report via Whistle blower, use the one of the following alternatives:
-E-mail to Kristiansson@kntr.se which goes to Björn Kristiansson, lawyer at Kanter Advokatbyrå KB, Stockholm.
-Letter to the address “Sensys Gatso Whistle Blower, C/O Kanter Advokatbyrå KB, Box 1435, 111 84 Stockholm, Sweden ”. The letter will be forwarded to Björn Kristiansson.
-Direct telephone contact at +46 7677 03747.
-Anonymous reports will be accepted, but contact details to the reporting person are appreciated.

Contact the police in case you believe that the internal process cannot be trusted.

5. How Sensys Gatso will respond
Sensys Gatso will be responsive and act upon any concerns raised under the Policy.
Please note that Sensys Gatso will be able to assess the merits of your concern only after having conducted an initial inquiry and, if necessary, after duly investigating the matter in question.

Where appropriate, the matters raised may:
-be investigated by management, the Board of Directors, internal audit, or through the disciplinary process
-be referred to the police or other law enforcement authorities
-be referred to the independent auditor

In order to protect the individuals involved and those suspected of the alleged wrongdoing, an initial enquiry will be made to decide whether an investigation is appropriate and, if so, what form it should take. If urgent action is required; this will be taken before any investigation is conducted. The overriding principle, which Sensys Gatso will have in mind, is the interest of the Company and its shareholders.

6. False and Malicious Allegations
Sensys Gatso is proud of its reputation and is striving to continue to meet the highest standards of honesty. It will therefore ensure that sufficient resources are put into investigating any complaint, which it receives. However, it is important for anyone contemplating making allegations to ensure that they are sincere and substantiated. No allegations should be made maliciously or with the knowledge that they are false.

7. Recommended structure of a Whistle Blower Report
-What has happened? Where has this happened? Please be as detailed as possible.
-When has this happened?
-Who was involved?
-Is this expected to happen again and if so, when and where?
-Which other persons may have knowledge of the above mentioned or may have access to relevant information?
-Is there any documentation or evidence available that may serve as evidence? If so, please include this information.
-Is there any other information that may be relevant or useful for the investigation or otherwise?

The above Code of Conduct was re-approved by the Board of Sensys Gatso AB on September 12th, 2018.