Whistleblower Mechanism
1. Applicability and Scope
This mechanism applies to all brands owned and operated by Offspring A/S, Wheat
Kids Clothing UK Ltd, Wheat Fashion Ltd, Wheat Norge AS
Each entity is responsible for implementing this mechanism in accordance with
applicable national legislation and regulatory requirements.
This mechanism is open to any external stakeholder, including suppliers, business
partners, customers, NGOs, or other third parties, as well as any individual or group
who may be adversely affected by Offspring A/S’ operations, products, or business
relationships.
2. Purpose
Offspring A/S is committed to conducting business responsibly and transparently
across our value chain.
This mechanism establishes a secure and fair process for external stakeholders to
raise concerns related to potential or actual adverse impacts linked to Offspring
A/S’ operations, products, or supply chain.
3. Scope of Grievances
This mechanism applies to grievances concerning:
• Violations of applicable law or regulations
• Human rights, labour rights, or workplace safety breaches in our supply chain
• Environmental harm linked to Offspring A/S’ operations or suppliers
• Corruption, bribery, fraud, or unethical business practices
• Misrepresentation of certifications, product claims, or ESG commitmentsOffspring A/S, Whistleblower Mechanism, 2026 version
4. Submission of Grievances
External stakeholders may submit grievances through the following channels:
Online form (confidential):
• https://wheat.dk/pages/whistleblower
• https://wheat.no/pages/whistleblower
• https://wheat.de/pages/whistleblower
• https://wheat.co.uk/pages/whistleblower
• https://wheat.eu/pages/whistleblower
• https://rethinkit-studios.com/pages/whistleblower
Email:
• whistleblower@wheat.dk
• whistleblower@rethinkit-studios.com
Written submission:
Offspring A/S
Attn. Whistleblower Committee
Grusbakken 12
2820 Gentofte, Denmark
5. Accessibility
This mechanism is publicly available via Offspring A/S’ brand websites.
Where appropriate, Offspring A/S will seek to ensure that affected stakeholders are
informed of the availability of this mechanism through supplier communication,
contractual requirements, or onboarding processes.
6. Grievance Handling Process
6.1 Confidentiality and Fair Process
• All grievances will be handled with strict confidentiality
• Identities of complainants will not be disclosed without consent, unless legally
required Offspring A/S, Whistleblower Mechanism, 2026 version
• Anonymous submissions will be accepted
• Grievances will be reviewed objectively and without bias
6.2 Investigation and Resolution
• Relevant Offspring departments (e.g. Compliance, ESG, Sourcing) will be
involved in the investigation
• Where the grievance concerns a supplier, the supplier may be contacted and
asked to provide evidence or corrective actions
• A corrective action plan may be developed where required
6.3 Remedy
Where Offspring A/S has caused or contributed to adverse impacts, we are
committed to providing for or cooperating in their remediation.
Where impacts are directly linked to our business relationships, we will use our
leverage to seek to prevent or mitigate the impact and enable access to remedy
where appropriate.
6.4 Communication of Outcomes
The complainant will be informed of the outcome, to the extent possible without
breaching confidentiality or legal obligations.
In cases involving systemic issues, aggregated findings may be disclosed in ESG
reporting.
7. Process Timeline
Offspring A/S will:
• Acknowledge receipt of a grievance within ten (10) working days
• Assess the admissibility of the grievance
• Inform the complainant of next steps and expected process timelines where
contact information is available
• Monitor implementation of agreed corrective actions where applicable
8. Recording and Data Management
• All grievances will be logged in Offspring A/S’ secure grievance system
• Records will include the nature of the grievance, findings, actions taken, and
outcomesOffspring A/S, Whistleblower Mechanism, 2026 version
• Data will be anonymized where appropriate and retained in line with GDPR
and Offspring A/S’ data protection policy
• Aggregated data will be reviewed annually to identify trends and inform ESG
risk management
9. Whistleblower Protection
External whistleblowers acting in good faith will not face retaliation, legal threats, or
blacklisting from Offspring A/S.
This mechanism does not replace access to judicial or administrative remedies and
may be used in parallel with other legal complaint procedures.
10. Responsibilities
• Whistleblower Committee: Receives, records, and ensures impartial handling
of grievances
• Relevant Departments (e.g. Compliance, ESG, Sourcing): Conduct
investigations and implement corrective measures
• Management and Board: Provide oversight and ensure grievances are
addressed at the appropriate level
11. Review of the Mechanism
This mechanism is reviewed annually to ensure compliance with applicable laws
(including the EU Whistleblower Directive) and alignment with best practices in
responsible business conduct.