Whistleblowing policy

1. Introduction

It is important for the company that any form of fraud, abuse, or injustice is reported and handled correctly. Therefore, the company encourages all individuals to raise any concerns they may have about others' behavior within the company or the way the company operates. This policy outlines how individuals can raise any concerns they may have and how these concerns will be handled.

This policy applies to all employees of the company, including full-time and part-time employees on fixed-term contracts, as well as others who perform functions for the organization, such as temporary workers and contractors, and is encouraged for external third parties or counterparts to use.

This policy and procedure are not contractual, and the company reserves the right to amend it if it decides to do so at its sole discretion.

2. Principles

Everyone should be aware of the importance of preventing and eliminating injustice in the workplace. Individuals should be vigilant about illegal or immoral behavior and report anything of this nature that they become aware of.  
Any case raised under this procedure will be investigated thoroughly, promptly, and confidentially, and the outcome of the investigation will be reported back to the employee who raised the concern.  
No individual will be victimized for raising an issue under this policy. This means that an individual's continued employment and future opportunities for promotion or training will not be prejudiced because they have raised a legitimate concern.  
Harassment of an employee for raising a qualified disclosure will be a disciplinary offense.  
If abuse is detected as a result of an investigation under this procedure, the organization's disciplinary procedure will be applied, in addition to any appropriate external measures.  
Maliciously making a false accusation is a disciplinary offense.  
An instruction to cover up wrongdoing is itself a disciplinary violation. If an individual is instructed not to raise or pursue a concern, even by an authority figure such as a manager, they should not accept remaining silent.  
This procedure is for information on issues unrelated to a breach of an employee’s own employment contract. If an employee is concerned that their own contract has been, or is likely to be, breached, they should use the organization's grievance procedure.

3. Policy

The law provides protection for those who raise legitimate concerns about specified matters. These are called "qualified disclosures."

A qualified disclosure is one made in the public interest by an individual who has a reasonable belief that:  
- A criminal offense  
- A failure to comply with a legal obligation  
- An action that creates a risk to health and safety  
- Financial fraud or mismanagement  
- An action that causes harm to the environment  
- Negligence  
- Breaches of our internal policies and procedures  
- Breaches of competition law or anti-competitive practices  
- A breach of any other legal obligation  
- Behavior likely to harm Howden Group Holdings and/or any associated subsidiary’s reputation  
- Concealment of any of the above has been, is being, or is likely to be committed.  

It is not necessary for the individual to have evidence that such an action is being or will be committed – a reasonable belief is sufficient. The individual is not responsible for investigating the matter – it is the company’s responsibility to ensure an investigation takes place.

4. Procedure

4.1 Step One
Initially, unless you reasonably believe that your line manager is involved in the wrongdoing, or if for any other reason you do not wish to approach your line manager, any concerns should be raised with your line manager. If you believe your line manager is involved, or for any reason do not wish to approach them, you should proceed directly to step three.

4.2 Step Two
Your line manager will arrange an investigation into the matter (either by investigating the matter themselves or immediately referring the issue to a more senior person). The investigation may involve you and other parties providing written statements. Any investigation will be carried out in accordance with the principles described above. Your statement will be considered, and you will be asked to comment on any additional information gathered.  

Your line manager (or the person carrying out the investigation) will then report to the board, which will take any necessary actions, including reporting the issue to relevant government departments or regulatory authorities. If disciplinary actions are required, your line manager (or the person who conducted the investigation) will report the matter to the HR department and initiate the disciplinary procedure. At the conclusion of the investigation, you will be informed of the outcome and what the board has done, or plans to do, regarding the matter. If no action is taken, the reasons will be explained.

4.3 Step Three*
If you are concerned that your line manager is involved in wrongdoing, has not conducted a proper investigation, or has not reported the results of the investigation to the board, you should inform the General Counsel ([email protected]), who will ensure that another leader reviews the investigation, conducts any necessary inquiries, and prepares their own report to the board as outlined in step two above. Any communication with the General Counsel will be treated confidentially, and your identity will not be disclosed without your prior consent.

4.4 Step Four
Where the matter is more serious, or you feel that your line manager or [insert contact person's role] has not addressed your concern, or you prefer not to raise it with them for any reason, you should cooperate with the independent confidential reporting line. Safecall provides the independent confidential reporting line, where you can raise your concerns and be assured they will be fully addressed. Calls are handled by trained staff and will be dealt with in full confidentiality. A report of the call will be sent to the Group General Counsel. Safecall will not disclose your name to Howden Group Holdings if you wish to remain anonymous.  

You can contact Safecall at any time on the free number: 00 800 7233 2255 (New Zealand)  
The Safecall line is available 24/7, 365 days a year. Alternatively, Safecall can be contacted via email at [email protected] or through the website www.safecall.co.uk/report.  

Details of the Safecall service can also be found on Safecall posters, which you can find in the office and on the intranet.

4.5 Step Five
If, after completing all of the above steps, you reasonably believe that the appropriate action has not been taken, you should report the matter to the relevant authority.  

The legislation specifies a number of bodies to which qualified disclosures can be made. These include:  
- The New Zealand National Bank and Ombudsman (NZ)  
- The Tax & Customs Authority  
- The Financial Supervisory Authority  
- The Competition and Markets Authority  
- The Health and Safety Executive  
- The Environmental Agency  
- Independent Policy Ombudsman.  

For Safecall international toll-free numbers, visit Safecall.