Our Commitment

The Group is committed to maintaining the highest ethical and professional standards and preventing any wrongdoing.

Examples of Wrongdoing

Examples of wrongdoing may include (but are not limited to) the following:

• A criminal activity;
• Failure to comply with a legal obligation– e.g. breach of competition law or a breach of any of the Group’s health and safety obligations;
• Breach of any of the Group’s operational/internal controls, processes and/or policies;
• Immoral, illegal or unethical conduct;
• Failure or likely failure to comply with any regulatory obligations whether general or specific to the business of any of the Group;
• Falsification of documents or reports;
• Financial irregularity, wrongdoing or misstatement;
• Fraud, theft or misappropriation of any of the Group’s funds;
• Improper use of any of the Group’s assets

If you have any concerns relating to any wrongdoing, please report it. You can make the report anonymously if you wish and any report will be treated in the strictest confidence.

It is not necessary for you to have proof that such an act is being, has been, or is likely to be committed as reasonable belief is sufficient. You are not responsible for investigating the matter as it is the Group’s responsibility to ensure that an investigation takes place and the matter is appropriately dealt with.

If your concern relates to a grievance you should in the first instance follow the procedure set out in the Grievance Policy. However if you do not feel comfortable doing this, you are able to raise your concern anonymously via this whistleblowing hotline and website and in this case the matter will in most instances be referred to by the Whistleblowing Panel your local HR team and/or Group HR.

Zero-Tolerance Approach to Victimisation

We appreciate that those reporting concerns about whistleblowing may be apprehensive. We want to reassure you that you will suffer no detrimental treatment as a result of voicing your genuine concerns.

The Group will not tolerate victimisation, harassment, bullying or any other detrimental treatment of any individual who has spoken up and made a disclosure under this whistleblowing policy. Complaints about such behaviours will be dealt with under the relevant local policy.

Should you feel you have been subjected to any detriment as a result of speaking up and raising a genuine concern under this policy you should notify your line manager or, if you do not feel comfortable doing this, you should notify your local Human Resources Manager.

To Make a Report

You may use either of the following two methods to submit a report:

After you complete your report you will be assigned a unique code called a "report key." Write down your report key and password and keep them in a safe place. After 5-6 business days, use your report key and password to check your report for feedback or questions.