Whistle-blower policy

The purpose of this policy is to establish a confidential and secure mechanism for employees and other stakeholders to report concerns about unethical, illegal, or fraudulent behaviour, without fear of retaliation or victimisation.

Scope
This policy applies to all employees, contractors, suppliers, clients, and stakeholders of Exchange Supplies, including but not limited to:

• Permanent employees;
  

• Temporary employees;
  

• Agency workers;
  

• Subcontractors;
  

• Consultants;
  

• Customers;
  

• Suppliers; and
  

• Other stakeholders.
  

Reporting Mechanisms
Whistle-blowers can report concerns through one of the following channels:

• Directly to the managing director;
  

• To their line manager or supervisor;
  

• To the designated Whistle-blowing Officer; and
  

• To the independent external whistle-blowing ethics advocate.
  

All reports will be treated confidentially and with sensitivity. Anonymous reports will also be accepted, but the company encourages whistle-blowers to provide their contact details to enable follow-up and further investigation.

The external whistle-blowing ethics advocate will offer a confidential channel for people to report by email or phone any concerns or wrongdoing they have witnessed or experienced, including behaviour that is not in keeping with our mission and values, ethical violations, fraud, or corruption.

Their main function is to protect the identity of the person making the report and ensure that the information provided is handled appropriately.

They will:

• Receive, investigate and act on reports in a fair, impartial and confidential manner, providing feedback and advice to the whistle-blower when necessary.
  

• Offer professional support and guidance to whistle-blowers on how to make a report and what to expect throughout the process.
  

• Investigate reported concerns and the gather evidence including interviews with relevant parties.
  

• Protect whistle-blowers against any retaliation or victimisation by the organisation or its employees.
  

• Collaborate with relevant authorities, if necessary, to ensure that reported concerns are addressed appropriately.
  

• Report and feedback on the types of concerns reported and actions taken to address them.
  

The independent whistle-blowing service is a resource for individuals who wish to report concerns about unethical or illegal behaviour without fear of retribution, and is in place because we strive to maintain a culture of integrity and accountability.


Protection and Confidentiality
Whistle-blowers will be protected from retaliation or victimisation for making a report in good faith. This includes protection from dismissal, disciplinary action, demotion, harassment, or discrimination.

Any attempt to retaliate against a whistle-blower will be treated as a serious disciplinary offence.

All reports will be treated with utmost confidentiality and will only be disclosed on a need-to-know basis for the purpose of investigation and resolution. Whistle-blowers will be informed of the progress of their report and the outcome of any investigation, where possible and appropriate.

Investigation and Resolution
All reports will be promptly investigated by the designated Whistle-blowing Officer, or our independent external whistle-blowing and ethics advocate.

Investigations will be conducted with objectivity, impartiality and fairness, and all parties involved will be treated with respect and dignity.

If the investigation confirms the reported concerns, appropriate actions will be taken to address the issue and prevent it from recurring. These actions may include disciplinary action, remedial measures, corrective action plans, and process improvement.

Retention of Records
All reports and investigation records will be securely stored and retained for a minimum of 7 years in accordance with applicable laws and regulations.

Training and Awareness
We will provide regular training and awareness-raising activities to all employees and stakeholders on the importance of whistleblowing, the process for making a report, and the protection and confidentiality provided to whistle-blowers.

Transparency
This Whistle-blower Policy will be published on our website for our customers to see, and on the Exchange Supplies online internal compulsory training platform.

Policy Review
This policy will be reviewed periodically to ensure its effectiveness and relevance, and to incorporate any changes in legislation or best practices. Employees and stakeholders will be informed of any updates or changes to this policy.

Signed:
[when completed]
Andrew Preston, Managing Director

Date: