Reporting a wrongdoing at Striive: how our whistleblower policy works

Why this policy exists
At HeadFirst Group, we consider integrity important. Do you suspect a wrongdoing? We offer you a safe way to report this. This policy lowers the threshold for reporting a wrongdoing and protects you when you do.

Who can make a report
You have a working relationship with HeadFirst Group if you:

• Work as an independent professional, intern, volunteer, temporary worker, or secondee
• Have applied for a role at HeadFirst Group
• Are directly involved with HeadFirst Group through your own work

Are you a partner of HeadFirst Group? Then this policy also applies to you.

What you can report
There are two types of wrongdoing you can report. First, societal wrongdoings: behavior with major harmful consequences for HeadFirst Group or for others. This often happens repeatedly and involves multiple people. Examples include behavior that may lead to criminal offenses, threatening intimidation of employees, possible corruption or bribery, or possible forced labor or child labor.

Second, violations of European rules: European regulations that may be violated, for example in the area of personal data protection, IT system security, consumer protection, or financial services. Examples include unlawfully destroying data, insufficient protection of personal data, or discrimination in the workplace.

Good to know
Your suspicion must be based on reasonable grounds. Did you witness something yourself? Then you can report it. Did you hear about it from a colleague? Then that colleague should report it themselves.

How to make an internal report
You report a suspected wrongdoing in writing via support@striive.com or by post, or verbally by phone via +31235685630. By post, you can write to:
HeadFirst Group, Taurusavenue 18, 2132 LS Hoofddorp

You will receive an acknowledgment of receipt within 7 days. Within a maximum of 3 months, you will hear more about the assessment and follow-up of your report.

How to make an external report
You can also report a suspected wrongdoing directly to a competent authority. You do not need to report internally first. Which authority you approach depends on the nature of the wrongdoing:

• Netherlands Authority for Consumers and Markets: for violations of consumer law
• Dutch Data Protection Authority: for violations involving personal data
• The Dutch Central Bank and the Netherlands Authority for the Financial Markets: for violations of financial-economic rules
• The House for Whistleblowers: for a wrongdoing that does not fall under the other categories. You can also go here for independent advice.

You are protected
Do you report a wrongdoing in good faith? Then you may not suffer any disadvantage as a result. People around you, such as your partner, family, or direct colleagues, are also protected. This protection covers at least:

• Non-continuation of your assignment
• Withholding of rate increases
• Denial of access to other assignments

If you breach your confidentiality obligation while reporting, you will not be held accountable for this, provided you act in good faith.

Your confidentiality is guaranteed
You can also report a suspected wrongdoing anonymously. HeadFirst Group treats your report confidentially. This applies at least to:

• Your identity, if you have not already reported anonymously
• Data about the persons your report concerns
• Information that can be traced back to this data
• Trade secrets

If we forward your report to another organization, we do so anonymously.