Whistleblowing Policy

1. Purpose

This policy enables directors, employees, contractors and partners to raise concerns about suspected impropriety — including corruption, criminal conduct, breach of legal obligation, danger to health or safety, or concealment of any of these — without fear of reprisal.

2. Making a disclosure

Concerns should normally be raised first with the Business & Legal Team. Where that is not appropriate, or where the concern is not addressed, a disclosure may be made to the external bodies named above, which the Whistleblowers Protection Act recognises as proper recipients of a protected disclosure.

3. Protection

• A whistleblower who makes a disclosure in good faith is protected from dismissal, suspension, harassment, discrimination or other occupational detriment.
• We will keep the whistleblower’s identity confidential so far as the law and the investigation allow.
• Where a whistleblower’s safety is endangered, the law provides for state protection.

4. How we respond

We will acknowledge a disclosure, assess it objectively, investigate proportionately and take appropriate corrective action. We will not tolerate retaliation against anyone who raises a genuine concern; doing so is itself a disciplinary matter.

5. Good faith

This policy protects honest disclosures. Knowingly false or malicious allegations are not protected and may lead to disciplinary action.