Ahold has a single and uniform Whistleblower Procedure that applies at both its U.S. and European operations which is designed to meet Ahold’s corporate governance obligations under Dutch law and international best practice. 
The Whistleblower Procedure provides all of Ahold’s employees with an avenue to raise any concerns they may have relating to their workplace or Ahold’s business practices outside of their normal management reporting lines. Ahold policy prohibits any retaliation against whistleblowers and the Whistleblower Procedure enables employees to make their reports on an entirely anonymous basis if they wish. As such, the Whistleblower Procedure is an important element of Ahold’s Global Ethics and Compliance program and central to our effort to establish and sustain an ethical workplace environment and sound business practices.
The Whistleblower Procedure consists of a hotline that employees can call toll free or access via the internet, 24 hours a day, seven days a week, to report issues that concern them. All calls are taken by a skilled interviewer and may be made anonymously if the caller so wishes. Details of all calls to the hotline are logged in a centralized database which is also used for documenting the investigation of the issues raised and the conclusions reached. Each Ahold Operating Company has a gatekeeper responsible for assigning every report received by the hotline or over the internet to the appropriate corporate function for investigation and for providing feedback to the caller. All reports received are investigated and followed up on. A summary of all issues reported through the Whistleblower Procedure, including but not limited to any issues regarding accounting or audit irregularities, is presented to the Audit Committee on a quarterly basis.


