Whistleblower Policy

Whistleblowing Policy 1st September 2024

Introduction

Employees may, in properly carrying out their duties, have access to, or come intocontact with, information of a confidential nature. Their terms and conditions providethat except in the proper performance of their duties, employees are forbidden fromdisclosing, or making use of in any form whatsoever, such confidential information.

However, the law allows employees to make a ‘protected disclosure’ of certaininformation. In order to be ‘protected’, a disclosure must relate to a specific subjectmatter (clause 2) and the disclosure must also be made in an appropriate way (clause3). Whistleblowing protection is confined to a disclosure which, in the reasonable beliefof the employee making the disclosure, is made in the public interest.

Eastron Europe Limited (“the Company”) is committed to compliance with the BriberyAct 2010. The Company actively encourages a culture of honesty and openness andtherefore all employees are required to bring up to their manager or other designatedperson any issue that, in the employee’s opinion, might constitute bribery or corruption.

Specific Subject Matter

If, in the course of employment, an employee becomes aware of information which theyreasonably believe tends to show one or more of the following:

That a criminal offence has been committed, is being committed or is likely to becommitted.
That a person has failed, is failing or is likely to fail to comply with any legal obligation to which he is subject.
That a miscarriage of justice that has occurred, is occurring, or is likely to occur.
That the health or safety of any individual has been, is being, or is likely to be, endangered.
That the environment, has been, is being, or is likely to be, damaged.
That information tending to show any of the above, is being, or is likely to be, deliberately concealed.
That the business or any associated person has been, is being, or is likely to be receiving or offering bribes.
That any foreign official has been, is being, or is likely to be bribed or offered facilitation payment by the company or any associated person they must use the Company’s disclosure procedure as set out below.

Disclosure Procedure

Information which an employee reasonably believes tends to show one or more ofthe above should promptly be disclosed to your Line Manager so that any appropriate action can be taken.
If it is inappropriate to make such a disclosure to the manager, the employee should speak to their Line Manager.
Employees will suffer no detriment of any sort for making such a disclosure in accordance with this procedure.
However, failure to follow this procedure may result in the disclosure of information losing its ‘protected status.’
For further guidance in relation to this matter or concerning the use of the disclosure procedure generally, employees should speak in confidence to a Director.

This policy has been approved & authorised by the management of Eastron Europe Limited.