NHG HQ Employee Handbook

EMPLOYEE

“Improving quality of life through specialised healthcare”

1

Table of Contents 1.

Founder’s mission statement ............................................................................................................................. 3

2.

Who we are ........................................................................................................................................................... 4

3.

Company services ............................................................................................................................................... 4

4.

Culture .................................................................................................................................................................. 5 4.1 Diversity and Inclusion of Employees and Ideas ................................................................................................... 6 4.2 Growth-mindset ..................................................................................................................................................... 6 4.3 Problem solving .................................................................................................................................................... 7

5.

Employee Development....................................................................................................................................... 7 5.1 Performance Reviews ........................................................................................................................................... 8

6.

Communication .................................................................................................................................................... 8 6.1 "The pyramid principle" ......................................................................................................................................... 9 6.2 "The communicative dogma"................................................................................................................................. 9 6.3 Prioritising Communication ................................................................................................................................... 9

7. Customer Acquisition Strategy ............................................................................................................................. 10 8.

Ethics and Conduct ............................................................................................................................................ 11

9.

Whistleblower Policy ......................................................................................................................................... 12

10.

Pleo, Travel and Expense policy .................................................................................................................. 13 10.1 Travels and expenses ....................................................................................................................................... 13 10.2 Pleo-card .......................................................................................................................................................... 14

11. Equipment Policy ................................................................................................................................................... 14 11.1 Provision of Work Equipment ............................................................................................................................ 15 11.2 Usage of Work Equipment ................................................................................................................................. 15 11.3 Maintenance and Care ...................................................................................................................................... 15 11.4 Data Security and Backups ............................................................................................................................... 15 11.5 Return of Work Equipment ................................................................................................................................ 15 11.6. Upgrades and Repairs ..................................................................................................................................... 16 11.7. Compliance and Consequences ....................................................................................................................... 16 12. Company Phone ..................................................................................................................................................... 16 12.1 Phone for Work-Related Use Only .................................................................................................................... 16 12.2 Phone for Both Work and Personal Use ............................................................................................................ 16 12.2.1 Tax Considerations ......................................................................................................................................... 16 12.2.2 Specific Guidelines for Work-Related-Use-Only Phones ................................................................................ 17 12.2.3 Specific Guidelines for Phones for Both Work and Personal Use ................................................................... 17 12.3 Misuse and Consequences ............................................................................................................................... 17 12.4 Responsibility .................................................................................................................................................... 17 12.5 Loss or Theft ..................................................................................................................................................... 18 12.6 Termination of Employment ............................................................................................................................... 18 13. Vacation, Maternity Leave Regulations and Child's First Sick Day .................................................................... 18 13.1 Vacation ............................................................................................................................................................ 18 13.2 Maternity Leave Regulations ............................................................................................................................. 18 13.3 Child's First Sick Day ........................................................................................................................................ 19 14. Data Ownership ...................................................................................................................................................... 19

2

1. Founder’s mission statement ________________________________________________________ ”In 2016, I founded Nordic Health Group with a vision to make the best treatments for varicose veins accessible to everyone, so no one would have to live with a reduced quality of life due to varicose veins.

Treatment for varicose veins has traditionally been expensive and of varied quality. It was difficult to find a specialist with an interest in providing the best treatments and who was regularly challenged and taught by other specialists.

One by one, we have found the best specialists and trained them further. Through our exclusive NHG Academy, we work continuously with surgeons, nurses, and researchers to create the best treatments and protocols, while keeping prices affordable. With the dedication of people, we are pioneers in making the best treatments not just a luxury, but a standard within reach for all.

Our commitment to excellence is not just a standard—it's a promise. Drawing inspiration from our Scandinavian heritage, we champion the principles of transparency, innovation, and unwavering dedication to progress. Our ambition, while unspoken, is to become the world's leading authority in varicose vein healthcare.

From the most advanced endovenous laser therapies to cutting-edge minimally invasive techniques, we're not only setting the bar in the industry—we're elevating it. Our vision is unwavering: a future where the challenges of varicose veins are not barriers to living life to its fullest."

3

2. Who we are ________________________________________________________ Nordic Health Group is a rapidly growing provider in the private healthcare sector, which contributes to a higher quality of life among our patients through specialised healthcare services.

As an employee at Nordic Health Group, it is important to know the mentality that prevails in the organisation and that paves the way for future development. It is therefore valuable that everyone works towards the same goal with aligned interests. We want to continuously strengthen the organisation's competitiveness by consistently working on the basis of a common set of values, which is made up of the following values:

Quality

Compassion

Efficiency

Commitments to clients

Constant improvement

3. Company services ________________________________________________________ At Nordic Health Group, we are dedicated to improving the quality of life for our patients by providing high-quality treatments for varicose veins and spider veins. Our comprehensive approach ensures that patients receive the most suitable treatment options tailored to their specific needs, enhancing both health and overall well-being. The treatments are carried out with the latest recognised treatment methods and in accordance with the latest research within medical science.

Varicose veins are enlarged, twisted veins that most frequently appear in the legs. They result from weakened vein walls and malfunctioning valves, causing blood to accumulate and create visible bulging veins. Varicose veins can lead to discomfort, pain, and cosmetic concerns.

Spider veins are smaller, visible blood vessels that often appear as fine red, blue, or purple lines 4

on the skin. They can occur on various parts of the body, including the legs and face, and are primarily a cosmetic concern but can also have physical symptoms.

We offer the following treatments: Endovenous Laser Ablation (EVLA): A minimally invasive procedure that uses laser energy to seal off and close varicose veins, redirecting blood flow to healthier veins.

Sclerotherapy: A non-surgical approach involving the injection of a specialised solution into varicose veins, causing them to collapse and fade.

Phlebectomy: A minor surgical procedure to remove surface varicose veins through small incisions.

Microsclerotherapy: This procedure is applied in treating spider veins, as it causes them to collapse and fade.

The treatments performed by the surgeon must always be performed with the latest and recognised treatment methods as well as otherwise according to proven and established medical science. Currently, we primarily use laser and secondarily foam (if laser cannot be used). The aforementioned treatments can be carried out in combination with phlebectomies if the customer pays for it.

4. Culture ________________________________________________________

We are committed to delivering top-quality varicose vein treatments to a broad range of patients. This involves expanding our reach into existing markets and exploring opportunities to establish our presence in new countries. Our goal is to provide the best treatment for varicose veins to as many people as possible. The priority in our goals is always to achieve a higher number of satisfied patients. We are proud to deliver the best quality to the customer, while at the same time ensuring efficient and healthy operation of the company.

Our organisation fosters an informal, egoless culture where everyone can contribute to each other's growth and improvement. We expect all individuals to be or work towards becoming the best at what they do. Engagement in the operation is highly valued. We take pride in delivering the highest quality to the customer. It is important to note that the customer and the patient are not always one and the same, and customers may have different treatment preferences to what we would have chosen.

We nurture a culture that is open, informal, and collaborative. We prioritise a culture where every team member is encouraged to help others develop and excel. We expect all employees to strive for excellence in their respective roles and actively engage in the business.

5

4.1 Diversity and Inclusion of Employees and Ideas At Nordic Health Group, we deeply value diversity and inclusion, not only in our workforce but also in the ideas and perspectives we bring to our decision-making processes. Our commitment to these principles is rooted in the belief that a wide range of experiences, backgrounds, and viewpoints drives innovation, enriches our workplace culture, and enhances the services we provide to our diverse client base.

We champion an environment where the best argument prevails, regardless of the speaker's position or tenure. This approach ensures that we are always open to the best ideas, fostering a culture of meritocracy and innovation.

By embracing different perspectives and ensuring equal opportunity for all employees to contribute, we not only make our team stronger but also mirror the diverse community we serve. Our focus on diversity and inclusion is integral to our mission of delivering exceptional care and solutions, ensuring that we always remain adaptable, relevant, and responsive to the needs of our patients and stakeholders.

4.2 Growth-mindset At Nordic Health Group, we champion a "Growth Mindset," a core principle that drives our personal and professional development. A growth mindset encourages viewing challenges as opportunities, valuing effort as a path to mastery, and seeing failures not as evidence of unintelligence but as a springboard for growth and for stretching our existing abilities. By fostering a growth mindset, we aim to create a workplace culture that values continual learning, resilience, and a constant pursuit of excellence.

In our daily operations and long-term planning, we encourage all team members to adopt this mindset. This approach means: • • • • • •

Facing difficulties with a positive attitude, understanding that each challenge is an opportunity to learn and grow.

Mistakes and errors are the key to growth.

Viewing setbacks not as failures but as part of the learning and development process.

Recognising that mastery and skill development take time and consistent effort.

Using constructive feedback as a tool for self-improvement and refinement of skills.

Rather than feeling threatened by others' success, using it as motivation to learn and grow.

This mindset is not just about individual development but also about contributing to a collaborative, innovative, and supportive work environment, where each member feels empowered to contribute, learn, and thrive.

6

4.3 Problem solving At Nordic Health Group, problem-solving is what we excel at. It is problems and obstacles that make us grow and develop. Therefore, we also recognise that challenges can arise in any workplace. Our approach to resolving these issues emphasises open communication and collaborative problem-solving.

We encourage all employees, irrespective of their position, to engage in open dialogues. If you feel there's an area of concern or a potential for improvement, we urge you to discuss it.

Conversations can be with peers, superiors, or any relevant party. The objective is to gain a clearer understanding of the issue and collaboratively identify solutions.

Steps for Resolution: • • • •

Identify the Concern: Clearly define the problem or dispute. Understand its root causes and the parties involved.

Engage in Dialogue: Initiate a conversation with the concerned parties. Approach the discussion with an open mind, ready to listen and understand different perspectives.

Seek Mediation: If direct communication doesn't resolve the issue, consider seeking a neutral third party within the organisation to mediate the discussion.

Document the Solution: Once a resolution is reached, document the outcome and the steps agreed upon to address the concern.

We believe in the power of open communication. We trust our employees to handle challenges maturely, always striving for what's best for both the individual and Nordic Health Group.

5. Employee Development __________________________________________________________ We highly value employee engagement and a sense of responsibility for the overall operation.

We encourage personal and professional growth and strive to facilitate the realisation of individual ambitions within the framework of the organisation. Employees are encouraged to take an active role in the development and success of our business. This includes demonstrating a strong commitment to personal and professional growth. We are dedicated to supporting and nurturing the ambitions and career aspirations of our employees while aligning them with the objectives of the organisation. Engagement in the company's as well as your own professional development is highly valued, and we therefore encourage our employees to contribute to continually challenging the status quo. It is expected that everyone works towards being the best at what they do, while it is also expected that all employees help everyone else to develop and become better.

7

5.1 Performance Reviews At Nordic Health Group, we believe in the continuous growth and development of our employees. Regular performance reviews are a cornerstone of this belief.

Performance reviews are conducted regularly to assess an employee's progress, achievements, and areas for improvement. The review will be conducted by the employee and a manager. The reviews typically contain, but are not limited, to the following: • •

•

•

Review of Previous Targets: A discussion on the targets set during the previous review, the progress made, achievements, and any areas of challenge.

Setting New Targets: Collaboratively setting new performance targets for the upcoming period. These targets align with the individual's role, departmental objectives, and the broader goals of Nordic Health Group.

Feedback Session: Constructive feedback from the manager regarding the employee's performance, highlighting strengths and areas for improvement followed by constructive feedback from the employee to the manager regarding areas for improvement between the employee and manager.

Employee's Input: A space for employees to share their insights, challenges faced, and seek guidance or support for the upcoming period.

It's essential to approach these reviews with an open mind, prepared to both give and receive feedback. The objective is not just evaluation but also collaboration, ensuring that every employee has the support and resources they need to succeed.

6. Communication We encourage a professional way of working, where we treat our colleagues, patients, customers and external partners with great attention, humility, and professionalism. It is therefore crucial that our external communication reflects this, which is why it is expected that communication is precise, correct, and professional.

Despite a work culture that is characterised by professionalism, seriousness and efficiency, it is also crucial that an informal culture prevails, where there is room for a laugh and where a healthy work-life balance is established.

It is very important that we at Nordic Health Group always communicate professionally. Poor communication can lead to disagreements and conflict, even if you feel that you are "in the clear".

In our communication we follow these two principles; 1. “The pyramid principle” and 2. “The communicative dogma”.

8

6.1 "The pyramid principle" When we communicate in writing, it is crucial that it is easy to read and understand. By starting with the conclusion or the most important thing first, you ensure that the reader sees the most important thing first and only then gets the in-depth information. It is not always that the reader has the time or opportunity to read the entire message.

Bullet points help to make it easy and clear to read the most important points and thus easily form an overview. So, make it a habit to distil the essence down into point form and use it at the start of the email.

You can subsequently elaborate and explain the individual points later in the email. This gives the reader the opportunity to read more about what is relevant and at the same time skip over the things that may be less relevant.

Before you send your email, always make sure to read it through an extra time. Even though we are busy, it is important that we prioritise this, as insufficient, incorrect or poorly worded written communication can easily lead to misunderstandings.

6.2 "The communicative dogma" Prioritise form of communication in the following order according to what is possible: 1. Walk: If possible, it is always preferable to talk together physically. Here it is easier to read each other's body language and signals and thus ensure that both parties feel understood.

2. Talk: If the above is not possible for various reasons, the next best thing is to call or talk virtually. Talking together makes it possible to deepen the points you have, as well as to decode the other party's tone of voice and articulation.

3. Write: Communication in emails can easily be perceived as being passive aggressive, as it can be more difficult to decipher mood, tone of voice or irony. Written language does not allow the same nuances as verbal language. Therefore writing, including mail, Slack, SMS etc, is the last choice if the other two are not possible.

However, the advantage of having something in writing is that you can easily return to it.

Therefore, we must always follow up with an email if a verbal agreement has been made regardless of whether it is a patient, a colleague, or business partner. Because even if an agreement has been made over the phone, it is ultimately our responsibility that the information gets through, is understood, and remembered.

6.3 Prioritising Communication In a dynamic and information-rich organisation like Nordic Health Group, it's crucial to effectively prioritise our communication, especially when it involves interrupting colleagues 9

or management. To navigate this, we can use a simple, yet effective framework based on three criteria: Urgent, Important, and Interesting.

1. Urgent: If a situation or information is acute and requires immediate attention, such as a critical issue affecting patient care or a significant operational disruption, it should be communicated immediately. In urgent cases, you should either call or physically approach the person concerned without delay.

2. Important: Matters that are significant but not immediately pressing fall under this category. This might include issues that need resolution within a few days or information that could influence decision-making processes. For important matters, you should send an email or schedule a meeting as soon as possible to discuss the issue.

3. Interesting: This category covers information that is useful or beneficial but not critical to immediate operations or decision-making. It might include general updates, ideas for future projects, or shared articles of interest. For such information, an email or a Slack message is appropriate as a first step.

By categorising information and communication into these three tiers, we ensure that our interactions are respectful of each other's time and attention, while also addressing organisational needs effectively. This structure aids in maintaining a productive, focused, and respectful workplace environment.

7. Customer Acquisition Strategy ___________________________________________________________

Our primary channels are 1) Contracts with the Public Healthcare, 2) Contracts with Insurance Companies, and 3) Private patients.

1. County Council Contracts are occasionally tendered. Therefore, we must keep ourselves updated on when they are available and ensure that we secure them.

2. Insurance Contracts are mostly tendered by insurance companies. Therefore, we must maintain regular contact with them to be informed about upcoming tenders.

3. Private Patients are primarily acquired through marketing efforts and satisfied patients (i.e., word of mouth).

Our objective is to be a market leader in terms of Return on Investment (ROI) in the healthcare sector. We benchmark ourselves against industry competitors but also seek learning and inspiration from other sectors. Our marketing mix mainly includes:

10

• • • • •

•

Search Engine Marketing (SEM): We utilise SEM strategies to enhance our online visibility and engage with potential patients effectively.

Print Media: Traditional print advertising remains an important component of our marketing approach, allowing us to reach a broader audience.

Public Relations (PR): Maintaining a positive public image and enhancing our reputation through strategic PR efforts is essential.

Influencers: Collaborating with influencers and industry experts helps us extend our reach and credibility in the market.

Alliances and Collaborations with Other Clinics, etc.: Establishing partnerships and collaborations with other healthcare facilities and stakeholders can open up new opportunities for growth and service enhancement.

Leveraging Existing Customers: Engaging our existing customer base through initiatives like gift cards and referrals helps in both customer retention and attracting new patients to our services.

8. Ethics and Conduct _________________________________________________________

At Nordic Health Group, we uphold the highest standards of ethics and conduct. Our commitment to ethical behaviour is integral to our mission of improving the quality of life through specialised healthcare. We expect all employees to adhere to these principles in their professional and personal conduct while representing the organisation. The following guidelines and expectations outline our ethical and behavioural standards: 1. Professionalism Expectation: Employees are expected to maintain a high level of professionalism in all interactions, both within the organisation and with external stakeholders. This includes being punctual, dressing appropriately, and treating colleagues, patients, and partners with respect and courtesy.

2. Confidentiality Protecting patient and company information is paramount. Employees must maintain the confidentiality of sensitive data and refrain from discussing confidential matters with unauthorised individuals. Breaches of confidentiality are subject to disciplinary action.

3. Conflict of Interest Declaration: Employees must promptly disclose any actual or potential conflicts of interest that may compromise their objectivity, independence, or ability to perform their duties impartially.

11

4. Compliance with Laws and Regulations Adherence: All employees are expected to comply with applicable laws and regulations related to their job responsibilities. Ignorance of the law is not an excuse, and violations can have serious legal and financial consequences for both individuals and the organisation.

5. Anti-Discrimination and Harassment Respect: We are committed to providing a safe and inclusive work environment free from discrimination and harassment. Employees should treat all colleagues and patients with respect, irrespective of their race, gender, sexual orientation, age, religion, disability, or any other protected characteristic.

6. Social Media and Online Conduct Professionalism: Employees representing the organisation on social media platforms or online forums should do so professionally and with care. Posts should not disclose sensitive or confidential information and should reflect positively on Nordic Health Group.

Refrain from Disparagement: Employees should avoid making derogatory comments about the organisation, colleagues, patients, or partners online. Negative comments can have a detrimental impact on the organisation's reputation.

By adhering to these ethical and conduct guidelines, Nordic Health Group maintains a strong commitment to integrity, transparency, and the highest standards of professionalism.

Violations of these principles may result in disciplinary actions, up to and including termination of employment.

Reported violations will be thoroughly investigated, and appropriate actions will be taken to address the issue, up to and including disciplinary measures.

9. Whistleblower Policy ___________________________________________________________

Nordic Health Group (NHG) is committed to maintaining the highest standards of integrity, honesty, and professionalism. This policy aims to provide a platform for employees and stakeholders to disclose any wrongdoing or unethical behaviour they may witness, ensuring the protection of those who report such issues.

1. Reporting Employees and stakeholders are encouraged to report any misconduct, illegal activities, fraud, or violations of company policies. NHG promises that any individual raising a concern will be protected from retaliation or adverse employment actions.

12

2. Procedure a. If you witness or suspect any wrongdoing, immediately report the matter to your immediate supervisor or manager. b. If you are uncomfortable reporting to your immediate supervisor or if the issue is related to the supervisor, you may report directly to COO Magnus Lysemose. c. All reports will be treated confidentially. Only individuals directly involved in the investigation or resolution of the issue will be informed.

3. Protection from Retaliation NHG strictly prohibits any form of retaliation against an individual who, in good faith, reports a violation or suspected violation. Any employee found to be involved in retaliatory actions will be subject to disciplinary action, up to and including termination.

4. Anonymous Reporting Employees can choose to report incidents anonymously. While anonymous reports are accepted, it is encouraged to provide contact details for a more effective investigation process.

5. Investigation All reports will be investigated promptly. The investigation will be impartial, and findings will be documented and kept confidential.

10.

Pleo, Travel and Expense policy

___________________________________________________________

Every penny we spend impacts our ability to serve our patients, customers, and partners better.

Misspending not only affects our bottom line but also diverts resources away from essential growth opportunities and innovations. By adhering to this policy, we ensure that our financial resources are channelled towards the most impactful initiatives, allowing us to grow and thrive in a competitive landscape.

10.1 Travels and expenses Your manager must approve all travel before booking, and you should use the most costeffective travel option available. The following guidelines apply to travel activity: 1. Trips (flights, trains, hotels) are always booked as early as possible and no later than three weeks before (if this is possible). Trips at short notice that cannot meet the above must be approved.

2. If travel activity between two destinations is recurring, it is the employee's responsibility to investigate whether there is a cheaper solution than one-way tickets.

13

3. Train is our preferred travel option unless the transportation by plane is less time-consuming.

4. Flights are generally booked based on the cheapest departure unless longer shifts are included, and direct flights are required.

5. Hotels are generally only booked if necessary or if the possibilities for transport home on the same day are limited. The company has an agreement with local hotels in some cities.

6. Hotels are always booked as the cheapest possible option at a reasonable distance 0-2 km from the workplace (1 person, 1-person room), incl. breakfast.

7. Catering applies to max three meals per day. Catering is the closest catering option and is within reasonable limits (sandwich, salad or similar).

8. We avoid using taxis and other expensive travel options, including expensive parking at the airport.

10.2 Pleo-card For all Pleo transactions the following must apply: • • • • •

A receipt that MUST be attached every time in Pleo.

A note in Pleo for the transaction.

A notice in Pleo for which manager approved purchases over 50 €. It must be approved before the purchase (Slack, email or SMS).

Which clinic the purchase refers to.

If you buy for someone else, it must be described.

It is illegal to book the purchase as a cost to the company if the above is missing and therefore the employee becomes responsible for the cost and the amount is deducted from the salary.

11. Equipment Policy _____________________________________________________________

The purpose of this policy is to ensure the responsible and secure use of work equipment by employees while safeguarding company assets and information.

14

11.1 Provision of Work Equipment 11.1.1 Nordic Health Group will provide necessary work equipment to employees based on their job roles and requirements. This may include laptops, mobile phones (see specific policy below), or other devices essential for their work responsibilities.

11.1.2 The type and specifications of work equipment will be determined by the management to ensure alignment with the needs of the organisation.

11.1.3 All work equipment issued remains the property of Nordic Health Group.

11.2 Usage of Work Equipment 11.2.1 Work equipment should be primarily used for business purposes. Occasional, minimal personal use may be acceptable, provided it does not disrupt work tasks and adheres to the company's acceptable use policy.

11.2.3 Work equipment must not be used for illegal activities, including, but not limited to, copyright violations, hacking, or the distribution of inappropriate content.

11.2.3 Employees are expected to adhere to company policies regarding data security, confidentiality, and the protection of intellectual property while using work equipment.

11.3 Maintenance and Care 11.3.1 Employees are responsible for the general care and maintenance of their work equipment. This includes protecting the equipment from damage, theft, or loss.

11.3.2 In case of equipment damage or technical issues, employees must promptly report the problem to the IT department or designated personnel for resolution.

11.4 Data Security and Backups 11.4.1. All work-related data should be stored on company-approved systems and platforms.

Regular data backups are encouraged, and employees should not rely solely on work equipment for data storage.

11.4.2. Employees are required to follow company policies regarding data security, encryption, and password protection to ensure the integrity of company information.

11.5 Return of Work Equipment 11.5.1. Upon resignation, termination, or when work equipment is no longer required, employees are responsible for returning all issued equipment promptly, and must be returned with all necessary passwords and no biometrical locks.

15

11.6. Upgrades and Repairs 11.6.1. Requests for equipment upgrades or repairs should be directed to management.

11.7. Compliance and Consequences 11.7.1. Non-compliance with this Work Equipment Policy may result in disciplinary actions, which could include termination of employment.

12. Company Phone ___________________________________________________________ The purpose of these guidelines is to clarify policies on the company phone and any private usage of company phones. At Nordic Health Group, not all employees have to have a companyphone. This is only applicable if you work full time or close to full time and will be determined by the manager. For all employees who will be provided with a company phone, it is essential to understand the rules for both work-related and private use of the company phone to maintain efficiency and comply with tax regulations and company policies. There are two options for selecting a company phone:

12.1 Phone for Work-Related Use Only Employees can choose to have a company phone exclusively for work-related purposes. The company will provide both the phone and the corresponding plan according to business needs.

This phone should not be used for personal purposes. This option may be suitable for employees who prefer to keep work and personal phone usage separate.

12.2 Phone for Both Work and Personal Use Employees can also choose to have a company phone that can be used for both work-related and personal purposes. This option provides greater flexibility and may be suitable for employees who prefer not to carry two separate phones. However, it also carries additional responsibility for adhering to the guidelines and potential tax implications. Initially, the company will provide both the phone and plan according to business needs. If an employee desires a different and more expensive solution, this is possible, but the employee is responsible for covering the difference between the desired phone and the one provided by the company.

This phone remains the property of the company but may be purchased by employees upon departure (see Section 7).

12.2.1 Tax Considerations Choosing a company phone with the option for private use has tax implications. Private use of a company phone is considered a taxable benefit and must be reported to tax authorities. It is the employee's responsibility to adhere to tax laws and report private usage accurately.

16

12.2.2 Specific Guidelines for Work-Related-Use-Only Phones The company phone should be used exclusively for work-related tasks, including calls, messages, emails, and calendar management.

Personal usage, including calls and messages, should be avoided entirely.

Avoid excessive use of mobile data or international calls and report any additional costs outside of the plan.

12.2.3 Specific Guidelines for Phones for Both Work and Personal Use Private use of the company phone is considered a taxable benefit and must be reported accurately to tax authorities by the individual employee.

Private use of the company phone should not result in unnecessary costs for the employer.

Avoid excessive use of mobile data or international calls and report any additional costs outside of the plan.

Avoid unnecessary expensive personal calls, roaming during personal travels, or international calls to personal numbers.

Purchases made through the plan should be related to work requirements; thus, personal purchases through the company's billing method should be avoided.

12.3 Misuse and Consequences Misuse of the company phone for private purposes, such as expensive calls, roaming during personal trips, or personal purchases through the company's billing method, should be avoided as much as possible.

It is the employee's responsibility to report any deviations, violations, or other misuse to the company.

Employees may be asked to reimburse any costs incurred by the company as a result of misuse.

Repeated misuse may lead to disciplinary measures.

12.4 Responsibility The employee is responsible for the correct use of the phone and compliance with the guidelines and its security. Any form of abuse, unauthorised access, or damage to the phone should be reported immediately to management.

17

It is the employee's responsibility to employ the highest possible security measures, such as passwords, biometric locks, and active remote access, which must always be enabled to protect both company data and personal information.

12.5 Loss or Theft In the event of loss or theft of the company phone, the employee should immediately notify management. Management will take the necessary steps to protect company data and remote access to the phone if necessary.

12.6 Termination of Employment Upon the termination of employment, the company phone must be returned in a functional state to management, including access codes and necessary logins, such as keycards, Apple IDs, and the like. All company data and apps will be removed.

If an employee, during their employment, had a phone for both work and personal use but chose a more expensive phone than the one provided by the company, the employee can purchase the phone based on the company's depreciation policy and applicable tax regulations.

13. Vacation, Maternity Leave Regulations and Child's First Sick Day __________________________________________________________ At Nordic Health Group, we recognide the importance of supporting our employees' family commitments alongside their professional responsibilities. Our policies on a child's first sick day, maternity leave, and vacation are guided by the following principles, in accordance with the prevailing legislation. Unless otherwise stated in individual contracts, these guidelines are followed, underscoring our commitment to our employees' well-being and family life.

13.1 Vacation Concerning vacation, we adhere strictly to the five weeks of annual leave as prescribed by the holiday law. Employees are required to schedule their vacations at least two months in advance with their immediate supervisor and register it in Planday. We encourage planning vacation time while keeping in mind the company’s peak seasons, ideally opting for periods outside these busier times. This practice helps ensure smooth operation and staffing within the company.

13.2 Maternity Leave Regulations In line with maternity leave laws, we provide leave options for new parents. It's important to note that while we support parents in taking the time off needed for the birth and care of their 18

newborn, we do not provide paid maternity leave unless otherwise specified in individual contracts. Our policy aims to support the wellbeing of the family unit and the early development of the child while following legal guidelines.

13.3 Child's First Sick Day We understand the need for a parent to be present for their child on their first day of illness.

While we do not offer paid leave for this, our policy allows employees the right to take time off to care for their sick child. This ensures that our employees can provide the necessary care and attention to their child without worrying about work commitments.

14. Data Ownership __________________________________________________________ This section clarifies the company's ownership of data and its rights to access and monitor data for legitimate business purposes while emphasising privacy considerations and data protection.

Nordic Health Group recognises the importance of data security and the need to protect both company and personal information. It is important to understand the ownership and control of data in the context of the employment relationship: 1. Company Data: All data, files, documents, emails, and information generated, transmitted, or stored on company-owned devices or within the company's network are the property of Nordic Health Group. This includes but is not limited to work-related emails, documents, databases, and any data stored on company servers or systems.

2. Employee Data: Personal data, such as personal emails, documents, and other information that employees may store on company-owned devices, may be subject to access by the company under certain circumstances, as described below.

Employer's Rights 1. Data Access: Nordic Health Group reserves the right to access and monitor all data stored or transmitted on company-owned devices or within the company's network.

This includes but is not limited to email communications, files, and other electronic data.

2. Business Necessity: Data access by the company may occur for legitimate business purposes, such as ensuring data security, compliance with legal obligations, and maintaining the efficiency and integrity of company operations.

19

3. Privacy Considerations: While the company respects the privacy of its employees, it is important to recognise that, in the interest of business necessity, the company may need to access and review data.

4. Data Protection: All data accessed by the company will be handled in accordance with data protection regulations and with due consideration for privacy.

It is essential for employees to be aware that the company may exercise its rights to access, monitor, and manage data as outlined above to protect its interests and ensure the responsible use of company resources.

By using company-owned devices and systems, employees acknowledge and consent to the company's rights and responsibilities regarding data ownership and access.

___________________________________________________________________

By signing below, you acknowledge and confirm that you have read, understood, and agree to the contents presented in this document.

Employer

Employee

Date Name Signature ____________________

Date Name Signature _____________________

20