Reporting Suspected Irregularities (Whistleblower Policy)

The Board of Management and the Supervisory Board for the Fugro Group of companies believe that it is important that its employees are offered adequate and safe procedures for reporting suspected irregularities of a general, operational or financial nature in any Fugro operating company, worldwide.

Introduction
An employee should use this procedure if they have reasonable grounds to suspect that an irregularity has occurred or is likely to occur with regard to:

• A criminal offence
• Violation of external rules and regulations
• Violation of codes of conduct applicable within the company
• The intentional provision of incorrect information to public bodies
• The environment has been, is being or is likely to be damaged
  and
• Attempts to suppress destroy or manipulate information relating to any of the above

This policy is intended for offences which are non-trivial in nature, and which relate to the business affairs of the organisation. Issues which relate to employees personal circumstances in the workplace should be raised through the line management structure, or with Human Resources.

Reports can be made in the language of your country of origin. Anonymous reports will be investigated provided they contain sufficient detail to allow investigation. Your report will be treated confidentially unless the result is a criminal or civil action, in which case a statement will be required.

Non retaliation
Any employee, who reports a suspected irregularity that he or she reasonably believes to be true, can do so without the risk of retaliation. Employees who report a breach will be given protection and will not be put at a disadvantage as a result of his or her report. This protection will also apply if you are involved in the suspected irregularity, provided that you acted in good faith at the time of the offence which you are now reporting.

Misuse of the procedure for reporting suspected irregularities
We welcome reports which are made in good faith, if it should become clear that the procedure has not been used in good faith (for example, to pursue a personal grudge against another employee) this will constitute misconduct.

Procedure for reporting suspected irregularities
If you suspect that an irregularity is taking place, you are encouraged to discuss it in the first instance with your direct manager or supervisor. This method is encouraged because this is the fastest way to clear up any misunderstandings and to ensure an open working environment throughout the organisation.

If however this is not possible, is inappropriate or if you are dissatisfied with the outcome, you should raise the issue with the Confidential Advisor:

Wouter Mulders
Company Secretary of Fugro N.V.
E-mail:
Tel.: +31 70 3111109
Mob.: +31 6 22604161

The manager or confidential advisor will compile a report obtaining sufficient detail to allow an investigation to take place. You will be asked to sign and date this report, and you will be given a copy of it. You will be asked to keep the report confidential.

The manager or Confidential Advisor will immediately inform the Chairman (CEO) of the Board of Management of the suspected irregularity, who will arrange for a suitably qualified person to carry out an investigation. The details of the suspected irregularity will remain confidential, and no information will be provided to third parties without the consent of the Chairman of the Board of Management. If it is necessary to provide information, the name of the employee will not be disclosed, and the information will be provided in such a manner as to safeguard the anonymity of the employee.

Within eight [8] weeks of the date of the report, the employee will be advised of the status of the reported suspected irregularity by the Chairman of the Board of Management in writing, and of any action taken as a result.

In the event that information about the status of the reported suspected irregularity cannot be made within eight [8] weeks, the employee will be informed, and a new date will be set. If the employee is not satisfied with the outcome of the report, or has doubts about whether his/her concern is being properly dealt with, they have the right to appeal to the Chairman of the Supervisory Board.

On receipt of an appeal, the Chairman of the Supervisory Board will ensure that an investigation takes place, and will report the outcome of the investigation to the employee in writing within eight weeks.

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