Code of Conduct and Complaints Procedure Rinkel Film B.V.

Version 2.2 – May 2025

Definitions
Company, employer, and/or Client: Rinkel Film B.V.

Employee(s): Natural person connected to the employer's organization. This includes a natural person who has performed work for the employer, now or in the past, with or without an employment contract or appointment. This also includes an employee of another organization who works for the employer as a contractor, subcontractor, partner, or temporary worker.

Participant(s): all individuals including but not limited to participants, cast, and crew involved in the production.

Confidential Advisor: An individual appointed or designated by the management of our company with whom employees or participants can discuss confidential matters. The confidential advisor represents the interests of the employee or participant regarding those confidential matters.

Purpose
In order to be professional, ethical, and reliable as a company, we believe it is crucial that everyone involved in our company, including employees and participants, ensure that the right attitude is adopted and the correct behavior is exhibited. Everyone must feel safe. Key concepts include equality, respect, integrity, and honesty. This code of conduct describes the frameworks and agreements that must be observed. This code of conduct also provides insight into unwanted behavior, aiming to protect employees or participants from such actions. This ensures a positive work environment. Additionally, this code of conduct is intended to provide employees and participants with an opportunity to report misconduct or file a complaint. The code of conduct and complaints procedure should encourage employees and participants to report and engage in a conversation with us or an external party. By making the procedure transparent, the regulation provides guidance to employees and participants in case of unwanted behavior, misconduct, or a complaint.

Laws and Regulations
Naturally, every employee and participant, as well as the employer, must comply with the relevant national and international laws and regulations. Every employee and participant is also required to comply with the company's (internal) rules, including this code of conduct. We also ask every employee to consider the (unwritten) general norms and values within our company.

Unwanted Behavior

Discrimination
Article 1 of the Constitution states that all individuals in the Netherlands should be treated equally in similar circumstances. Discrimination based on religion, belief, political affiliation, color, gender identity, sexual orientation, or any other grounds is not permitted. Indirect discrimination is only allowed if there is an objective justification. In other words, there must be a valid reason for the distinction, which must be assessed on a case-by-case basis.
Bullying

The consequence of bullying is that in most cases, another person is intentionally hurt or humiliated. This can involve one or more employees/participants towards another employee/participant. Bullying also means that the behavior or omission has a structural nature, meaning it is repeated. It can manifest in various (non-exhaustive) ways, such as through words, threats, exclusions, or gestures.

Abuse of Power
Abuse of power can occur when a person takes advantage of their position of power, for example, by directing the behavior of others in a way that primarily benefits themselves. Or by making other individuals do things they do not want to do.

Sexual Harassment
Sexual harassment involves sexually suggestive verbal, non-verbal, or physical behavior. Sexual harassment results in compromising the dignity of the employee/participant. It can involve ambiguous comments, sending inappropriate messages or images, (unnecessary) touching, assault, and rape.

Aggression and Violence
Aggression involves the verbal or physical harassment, threats, or attacks against the employee/participant. This can include insulting, shouting, hitting, pushing, threatening, humiliating, and blackmailing.

Steps
If an employee/participant feels mistreated, the following steps should be taken:
Step 1: the employee/participant who feels mistreated may, if they feel comfortable and wish to do so, engage in a conversation with the employee/participant who caused this, to explore if a solution is possible. If the employee/participant is not comfortable with this step, it can be skipped.
Step 2: if the previous step does not lead to a solution or is not feasible given the situation, or not desired by the employee/participant, the employee/participant should report to the confidential advisor. The confidential advisor will listen to the complaint and provide advice, support, and guidance to the employee/participant in this matter. Additionally, the confidential advisor may engage with the parties to try to reach a solution.
Step 3: if the previous steps have been taken and it is not possible to resolve the unwanted behavior issue satisfactorily, the employee/participant has the option to file a complaint as described below.

Complaints Procedure
The employee/participant should submit the complaint in writing to the management via reinier@rinkelfilm.com, or to Stichting Mores. The management will then conduct an investigation into the unwanted behavior. During the investigation, the management will listen to both parties separately if requested by the employee/participant. Additionally, the management may hear other parties if deemed necessary. Parties will be given the opportunity during the investigation to become aware of each other's positions and respond to them. After the investigation, a written report will be prepared and sent to the parties. At the beginning and during the procedure, the employee/participant may request the management to take temporary measures. This will be done if deemed necessary by the management. An anonymous complaint cannot be processed.

Measures Against Unwanted Behavior
We take reports and complaints extremely seriously and will always intervene. This may involve temporarily suspending a shoot or, for example, removing an important crew member or actor from the set (temporarily). Our company takes responsibility in these situations, and it is important for us that anyone who wants to report or lodge a complaint does not feel obstructed or guilty (about the measures we take). If an employee engages in unwanted behavior, this may, at our discretion as the employer, be a reason to impose an appropriate labor law measure, including terminating the employment contract. If a participant engages in unwanted behavior, this may, at our discretion as the company/Client, result in sanctions, including but not limited to a warning or (immediate) exclusion from (further) participation in the program or another project. If the Client decides to impose a sanction, the Client is in no way obliged to compensate the participant or otherwise obligated to compensate the participant.

Shared Responsibility
It is paramount that everyone feels safe and accepted in the work environment, such as on the set. If something inappropriate is observed by someone, we request everyone (as far as possible) to address it directly with the individual. We ask everyone to collectively take responsibility for identifying and reporting misconduct.

Suspected Misconduct
An employee or participant who suspects misconduct can report it if the suspicion is based on reasonable grounds. The suspicion must be derived from the knowledge the employee/participant has acquired at the company or from the knowledge the employee/participant has gained through their work or tasks at another company.

Internal Confidential Advisor
The employee or participant also has the option to consult a confidential advisor. Stichting Mores has been appointed as the confidential advisor for our company.

External Confidential Advisor and External Reporting Point
Our company is affiliated with the Reporting Point for unwanted behavior in the Dutch cultural and creative sector (Mores). Mores can be approached by anyone working in the cultural and creative sector. This reporting point and the confidential advisors working for it are completely independent. You can choose to speak to an external confidential advisor if you find it more comfortable. You can also choose to report to Mores if you do not wish to do so directly to our company.

Confidentiality
Often, an employee or participant is subject to a confidentiality clause in the context of the employment contract. We note that in the event of reporting inappropriate behavior or unwanted behavior, the confidentiality clause (with a penalty clause) does not apply. The confidentiality clause should never be a barrier to reporting inappropriate behavior or unwanted behavior. This means that an employee is always entitled to share information that is relevant to the report with internal or external confidential advisors, or with the police.

Code of Conduct
Addictive and Narcotic Substances
Employees or participants do not use addictive or narcotic substances during work, unless prescribed by a doctor. The use of addictive or narcotic substances outside of work is also prohibited if it affects the performance of the function or task.

Conflict of Interest
Employees act in the interest of the company, which means that:

• any situation (or appearance thereof) is avoided if there may be a conflict of interest between business and personal matters;
• any potential conflict of interest is reported to the supervisor;
• company resources, (business) information, or the position within the company are not used for personal (personal) benefit or gain;
• the supervisor is informed if a gift or invitation is offered with a value above 25 euros.

Confidential Information
Employees handle confidential information carefully within and outside the company, which includes:

• company property is not left unattended;
• company documents (or data carriers) may not be taken outside the company without written permission from the management;
• documents containing sensitive business information or personal data must always be destroyed by depositing them in the designated bins;
• only data necessary for performing the tasks may be exchanged;
• no confidential data is sent to private email addresses;
• no confidential data is stored on or copied to private data carriers;
• strict confidentiality is maintained regarding confidential (business) information.

Company Resources
Employees handle the company resources allocated to them with care. Damage or loss of company resources or data is reported immediately to the supervisor. The employee may be held liable for the damage if it results from deliberate intent or culpable negligence by the employee.

Use of the Internet (and Visiting Websites)
It is not permitted to view or download pornographic, racist, discriminatory, offensive, or otherwise objectionable material via the internet. If unsolicited material of this nature is offered, it should be reported to the supervisor or the management.

Business email addresses are not to be used for personal purposes or to send messages anonymously or under a fictitious name, or to electronically harass someone. The employer has the authority to monitor the above agreements.

Use of Social Media
For all projects, there is a specific social media instruction for employees/participants that must be followed. This instruction is communicated in writing to the employees/participants. The instruction outlines what employees and participants may and may not share about and around the project in relation to the news value of information regarding the project. In the case of projects, it may be desirable that various components are not yet or only at specific times made public.

For a publication, such as a press release or announcement about a project by an employee on social media, an employee always requires prior written consent from our management. As a company, we want to maintain control over the information being shared about a project. From a commercial perspective, it may be desired that we handle such a publication as a company. Of course, employees or participants are always free to share a publication that has already been done by our company on their own social media.

Subject to project-specific instructions, employees and participants are free to use their own social media. Our employees ensure that they use their own social media under their own name and not on behalf of our company. This means that employees do not use an email address referring to our company.

Employees and participants must remain aware of the impact of statements on social media. Especially when it involves a negative statement. What is written in public is indelible. The context in which something is posted can also be important. In this regard, we want to inform employees and participants that we provide an opportunity to discuss issues with a confidential advisor.

Media Policy
If our company is approached or visited by the press, employees should never speak to the press. Prior consultation with the management must always take place before a response is given to the press. Be aware that journalists may try to provoke reactions and may put words in your mouth. Do not respond and correct a journalist if words are attributed to you.

Fraud and Theft
In the case of theft or fraud by the employee or participant, a 'zero tolerance' policy applies. Appropriate labor law measures (such as suspension or dismissal on the spot) or exclusion from participation in the production and reporting to the police will be taken.

Professional Work Environment
Employees and participants should treat not only each other but also all individuals involved in our company in a respectful and equal manner. Employees are expected to contribute to a safe and pleasant work environment for everyone.

Reporting Point
Employees who observe behavior that violates the code of conduct should report this to their supervisor. Participants who observe behavior that violates the code of conduct should report this to the management of our company via reinier@rinkelfilm.com or rinskje@rinkelfilm.com. The employee or participant who reports a violation of the code of conduct in good faith will be protected and will not suffer any disadvantage in their position or task as a result.

Enforcement of the Code of Conduct
Violating or not adhering to the code of conduct may be a reason to impose an appropriate labor law measure, including termination of the employment contract.

Final Provision
This regulation is subject to Dutch law. In the event that a provision in this regulation is wholly or partially invalid or void, a provision that best aligns with the text and intention of the original provision automatically takes effect. We are authorized to amend this code of conduct and complaints procedure due to, for example, changes in legislation or significant changes in business conditions.