Whistleblowing: Speak Up Service

James Fisher & Sons Plc (“JFS”) is committed to conducting business with honesty, openness and accountability throughout JFS and all of its affiliated companies (“the JFS Group”). JFS is an organisation with strong values of responsibility and integrity and encourages speaking-up and reporting conduct that does not reflect this commitment or which may be unlawful.

Our Whistleblowing policy applies to the JFS Group, its directors and all employees, contractors and, when applicable, all related third parties working for the JFS Group at all levels and grades wherever located. Whistleblowing reports made in accordance with our Whistleblowing policy may be submitted by any current or former employees, directors, customers, suppliers and associates of the JFS Group, including their family members and dependents (“Eligible Reporters”).

Protections for Whistleblowers

Any person submitting a report in accordance with the Whistleblowing policy will be afforded the protections set out in the Whistleblowing standard.

JFS is committed to ensuring that Whistleblowers do not suffer any detrimental treatment as a result of raising a concern. Any person found to have threatened a whistleblower and/or who has taken any retaliatory action against a whistleblower in any way will be subject to disciplinary action.

Anyone who considers that they may have suffered detrimental treatment as a result of making a report in accordance with the Whistleblowing policy should inform either the Chief Financial Officer or Chief HR Officer immediately.

Duty to Report

When we are confronted with any event that may reasonably amount to a Reportable Matter in relation to the JFS Group, we are all required to report such an event as soon as possible.

What is a Reportable Matter?

A Reportable Matter includes, but is not limited to, information about conduct that may relate to:

1. Criminal activity;
2. Failure to comply with any legal obligation or regulatory requirement;
3. Dangers to health and safety;
4. Damage to the environment;
5. Non-compliance with any JFS policy, standard, procedure or applicable legal requirements;
6. Unethical or unprofessional behaviour, including conduct that does not meet the JFS commitment to its employees, customers, regulators, shareholders or the community;
7. Issues of dishonesty, including financial fraud or mismanagement, facilitating tax evasion, theft, bribery and corruption;
8. Conflicts of interest, including those related to outside business interests or relationships;
9. Breaches of privacy or confidentiality, including in relation to the JFS Group or customer information;
10. Human rights abuses;
11. Inappropriate workplace behaviours, including bullying, discrimination or harassment; and
12. The deliberate concealment of any of the above matters.

Eligible Reporters must report anything that they may have reasonable grounds to suspect concerns a Reportable Matter relating to the JFS Group.

How to make a Whistleblowing Report

Whistleblowing reports should, where possible, be made in the first instance to your direct line manager or the direct line manager of your line manager. If this is not possible or you feel uncomfortable doing so for any reason, a report should be made to one or more of the following:

• Division General Counsel
• Division Head of HR
• Division Finance Director
• Group Head of Ethics & Compliance
• Group General Counsel

Alternatively, a report can always be made to the Speak Up Service using the links provided below. Reports can be made either online using the link below or by telephone by calling the relevant telephone number provided below for the country in which you are located.

Whistleblowing reports to the Speak Up Service can be made on a named or anonymous basis. The Speak Up Service is hosted by a third-party hotline provider, NAVEX using their EthicsPoint platform. The information you provide via the Speak Up Service either using the online form or by calling the relevant number below will be treated confidentially and in accordance with the JFS Whistleblowing standard and Whistleblowing Reporting and Investigation procedure.