Whistleblowing Policy

Our reporting process gives people a confidential way to raise concerns about suspected wrongdoing connected with our operations. A report may relate to conduct that has happened, is happening now, or could reasonably occur. People do not need to have complete proof before speaking up, but they should share the information they have and explain why they believe a concern may exist.
Concerns can include possible breaches of law, fraud, bribery, misuse of company resources, mistreatment of workers, or harm to the environment. Reports may also address attempts to conceal misconduct or failures to follow internal policies, ethical sourcing requirements, or sustainability commitments. The process is intended to identify problems, assess risks, and support appropriate action when a concern is substantiated.
This framework applies across the organization and its wider business relationships. Employees, temporary staff, contractors, consultants, and external partners may all raise concerns about relevant conduct. We encourage people to report issues through the available reporting channels, whether the matter concerns a single incident or a pattern that may point to a broader weakness in business practices or supply networks.
We take reports seriously and aim to handle them fairly. After receiving a submission, we will acknowledge it as soon as practicable and carry out an initial review. This review helps determine whether the information falls within the scope of the reporting process, whether further details may be needed, and what steps should follow. A report may be referred to a suitable specialist team where this is necessary to assess the matter appropriately.
When further investigation is warranted, trained compliance personnel may gather information and review relevant records. Depending on the issue, this may involve confidential conversations with people who have knowledge of the events, examination of documents, or consultation with other qualified specialists. Investigations are conducted with care and impartiality, while respecting privacy and applicable legal requirements. People involved in an investigation may be invited to bring an appropriate support person or authorized representative to a discussion, where permitted.
We seek to protect people who raise concerns in good faith from retaliation. Retaliation may include threats, unfair treatment, exclusion, discrimination, or other negative consequences connected with making a report or assisting with an inquiry. Anyone who believes they have experienced retaliation should raise that concern through the reporting process so it can be reviewed. Information about a report is handled on a need-to-know basis, although complete anonymity or absolute confidentiality may not be possible in every circumstance, particularly where a fair investigation or legal obligation requires disclosure.
People who submit a report may receive updates about the progress of the review, subject to privacy, confidentiality, and legal restrictions. The level of detail we can provide may depend on the nature of the allegations and the rights of others involved. We aim to keep communication open where possible and may contact the reporting person for clarification or additional information.
If an investigation confirms a breach, appropriate steps will depend on the facts, the seriousness of the conduct, and relevant laws and policies. Possible responses may include changes to business processes, internal disciplinary measures, ending a commercial relationship, or referring information to a government or law enforcement authority. Not every report will lead to formal action, but each concern should be assessed thoughtfully and documented in accordance with applicable procedures.
Speaking up helps us identify risks that might otherwise remain hidden. We encourage anyone with a genuine concern to provide a clear account, including relevant dates, locations, people, and supporting information where available. Reports should be made honestly and without knowingly providing false information. Our aim is to review concerns responsibly, protect those who participate, and strengthen accountability throughout our operations and business relationships.