Corporate Governance - Whistle-blowing Policy

General Statement
Heywood Williams Group PLC is committed to ensuring that the manner in which we operate and conduct our business is to the highest standard.

We recognise, however, that there may be occasions when employees have genuine concerns about the actions of their colleagues, managers or the operating company within which they work. The purpose of this Policy is to provide a framework for individuals to raise such concerns without fear of adverse repercussion.

Scope of the Policy
Employees should invoke the Whistle-blowing Policy where they have genuine concerns about any of the following:

Procedure

  1. Where an employee has a genuine concern about any of the above, the issue should normally be raised with his/her immediate line manager. If the employee feels unable to do so, the concern should be raised with a more senior manager (typically a Director of the operating company within which the employee works). If the employee feels unable to raise the issue with anyone involved in the operating company within which he/she works, the matter may be raised by phone or by writing to [DETAILS WITHHELD FOR PURPOSES OF CONFIDENTIALITY]
  2. The issue will be investigated as quickly as possible and the outcome communicated to the employee.

Confidentiality/Anonymity
Any concern raised under this Policy will be treated in confidence as far as is possible, subject to the need to ensure a full investigation of the issue.

A complainant may wish to remain anonymous and the Group will ensure the individual´s anonymity wherever possible and as far as is reasonably practicable.

Ultimately, however, the Group reserves the right to investigate any complaint raised under this Policy in the most appropriate manner to ensure that all aspects are fully and rigorously followed up. Where circumstances arise which mean that a full and thorough investigation cannot be conducted without revealing the identity of the complainant, this will be discussed with the individual concerned prior to any further action being taken.

Disciplinary Action
Where an investigation confirms that there has been wrongdoing/malpractice, appropriate action will be taken which may include summary dismissal and/or reporting the matter to the police/other statutory bodies.

The objective of this Policy is to provide a process to encourage individuals to raise genuine concerns. It may be, however, that the complainant has him/herself been involved in wrongdoing. In such a situation, he/she would have to answer for his/her actions and should not expect immunity from disciplinary/criminal proceedings. In such circumstances, however, the fact that he/she raised the concern would be taken into account.

Where it is found that an employee has abused the Whistle-blowing Policy and has made a deliberately false or malicious allegation, he/she may be liable to disciplinary action, which may result in dismissal.

Protection
The Group will take all reasonable steps to ensure that any employee who raises a concern under this Policy is not victimised or suffers any detriment.

Should an employee believe that they have been victimised or suffered a detriment or believe that their complaint has not been fully investigated, they should immediately contact [DETAILS WITHHELD FOR PURPOSES OF CONFIDENTIALITY]

Review of Policy
The Group Whistle-blowing Policy will be reviewed annually by the Audit Committee

In addition, the Directors are responsible for the preparation of the Directors´ Remuneration Report in accordance with the relevant legislation and other requirements.