Whistleblowing Policy for Talkwalker S.a.r.l

Last updated: July 7, 2025

Talkwalker is committed to carrying out our business in a safe, honest, and ethical way. Part of that is creating an open and supportive working environment where people feel able to speak up about any suspected wrongdoing. The Talkwalker Whistleblowing Policy for Luxembourg details our process for dealing with whistleblowing. It applies to all our Luxembourg employees and those Talkwalker S.a.r.l collaborators falling within the scope of the Luxembourg whistleblowing law.

For more information on whistleblowing, including what it is and what protection is provided, please refer to the Talkwalker Whistleblowing Policy available here.

Some points to remember:

• This is a Luxembourg specific policy.

  The Talkwalker Whistleblowing Policy ("Policy") only applies to employees and collaborators of Talkwalker S.a.r.l, and Trendiction S.A. (together for the purposes of this policy, “Talkwalker” ) as required pursuant to Luxembourg whistleblowing laws. If you are an employee of, or collaborate with, any other Talkwalker entity, the Policy does not apply to you.

• You must act in good faith.

  You don’t need to have any proof that something is happening. As long as you have reasonable grounds to believe, given the circumstances and the information available to you at the time of reporting, that the matters you report are true, you should report your concerns. But if we find that you’ve knowingly made a false allegation, we may deal with this under our disciplinary procedure.

• Personal grievances are not in scope.

  If you’ve got a personal complaint or concern, like about how you’re being treated at work, this isn’t a whistleblowing matter. It would be covered under our applicable workplace policy/guidelines.

Blowing the whistle

If you need to raise a concern, here’s how you can go about doing it:

• Your manager (if you are a Talkwalker employee)

Contact your manager, someone else in your reporting chain, or any other manager outside of your reporting chain.

• Other reporting channels

If you feel that you can’t raise your concern with your manager, or if you have but you've still got concerns, you can submit a concern through the webform located below.

Your report needs to include what your concern is, why you think it’s true and any other details you can give us. Remember to include your contact details. We may need to get in touch to talk about your concerns or to get some more details.

You can raise your concerns anonymously if you like and we’ll take these seriously. But it may be difficult for us to do a proper investigation if we can’t talk to you about other information we might need.

• External reporting

If you have reasonable grounds to believe that there is a risk of retaliation against you or a low chance of the matter being effectively remedied by Talkwalker, then you do have the option of reporting the matter to a relevant public authority or institution with expertise in the subject matter of the concerns you have raised.

The law lists the competent authorities in article 18 of Luxembourg’s whistleblowing laws and these include:

• The Luxembourg Financial Services Authority - CSSF

• The Luxembourg Insurance Commission - CAA

• The Luxembourg competition authority

• The Luxembourg Registration Duties, Estates and VAT Authority - AED

• The Luxembourg Inspectorate of Labour and Mines - ITM

• The Luxembourg Data Protection Commission - CNPD

• Public disclosure

Public disclosures are disclosures to the media, professional organizations, trade union, non-governmental organizations, parliamentary committees.

Although not prohibited, Talkwalker’s view is that it will very rarely, if ever, be appropriate to raise a whistleblowing concern directly to the media.

If you choose to publicly disclose information regarding a violation of the law, you may only benefit from protection afforded under Luxembourg’s whistleblowing laws if one of the following conditions is met:

• You first reported internally and externally or directly externally but consider that appropriate measures were not applied within the term provided by law; or

• You have good reasons to consider that:

1. the violation may constitute an imminent or obvious danger to the public interest or the risk of irreparable damage; or

2. in the case of external reporting there is a risk of retaliation or a low probability that the violation will be effectively remedied given the specific circumstances of the reporting.

Talkwalker’s designated whistleblowing team

Access to reports received through our reporting channel is restricted to appointed individuals at Talkwalker with the authority to handle whistleblowing cases. Their actions are logged, and handling is confidential. The Talkwalker legal team (located in the UK and EU) is the designated department dealing with reports. When needed, individuals who can add expertise may be included in the investigation process. These individuals can access relevant data and are also bound to confidentiality.