Ekco is committed to the highest standards of openness, probity, and accountability. An important aspect of accountability and transparency is a mechanism to enable all employees to voice concerns in a responsible and effective manner. To ensure all concerns can be raised in a responsible and effective manner to appropriate personnel, we have developed this Whistleblowing Policy.

Scope

This policy applies to all Ekco employees, including directors, permanent & part-time staff, contractors, suppliers, and agents. Concerns that may apply to this policy include:
• Financial malpractice, impropriety, fraud, or other criminal activity;
• Failure to comply with legal obligations or statutes;
• Dangers to Health & Safety or to the Environments;
• Improper or unethical behaviour;
• Racial, sexual, or other discrimination;
• Or any other unethical conduct.
This is a non-exhaustive list and are provided as examples only.

Policy Principles

This policy is designed to enable employees of the Company to raise concerns internally and at a high level and to disclose information which the individual believes shows malpractice or impropriety. The policy is designed to offer protection to those employees of the Company who disclose such concerns provided the disclosure is made in good faith and in the reasonable belief of the individual making the disclosure that it tends to show malpractice or impropriety.

In most cases it is anticipated that an employee should be able to raise any concern with their line manager. However, where they prefer not to raise it with their line manager, they should contact the People Operations team directly. The Company is fully committed to dealing with all genuine concerns, raised in good faith in an appropriate, responsible, and professional manner.

Raising Concerns

If the complainant is not satisfied that their concern is being properly dealt with by their line manager, or by the People Operations Team, they have the right to raise it in confidence with the Chief Operating Officer.

Whistleblowers must not suffer any detrimental treatment as a result of raising a genuine concern. If you believe that you have suffered any such treatment, you should inform the Head of People Operations immediately. If the matter is not remedied, you should raise it formally using our Grievance Procedure.

Confidentiality

Whilst it is not currently possible to make a whistleblowing report anonymously. Ekco will make every effort to keep the identity of a complainant confidential and to only reveal it where necessary to fully investigate an allegation.

Untrue Allegations

If an individual makes an allegation in good faith, which is not confirmed by subsequent investigation, no action will be taken against that individual. In making a disclosure the individual should exercise due care to ensure the accuracy of the information.

If, however, an individual makes malicious or vexatious allegations, and particularly if he or she persists with making them, disciplinary action may be taken against that individual.

External Disclosures

The aim of this policy is to provide an internal mechanism for reporting, investigating, and remedying any wrongdoing in the workplace. In most cases you should not find it necessary to alert anyone externally.

The law recognises that in some circumstances it may be appropriate for you to report your concerns to an external body such as a regulator. We strongly encourage you to seek advice before reporting a concern to anyone external.. The following section includes contact details for

Contact Information

Ireland Transparency Legal Advice Centre (“TLAC”) is Ireland’s only independent law centre specialising
in providing free legal advice to anyone who wishes to disclose wrongdoing as provided for under
Irish Law, particularly under the Protected Disclosures Act 2014 – Ireland’s primary legislation
protecting whistleblowers.
• Help Line: 1800 844 866
• Email: helpline@transparency.ie
• Website: www.transparency.ie
UK Protect (Independent whistleblowing charity)
Protect aims to make whistleblowing work for individuals, organisations and society. Protect
offer free expert and confidential advice on how best to raise your concern and your protection
as a whistleblower
• Advice Line: 020 3117 2520
• E-mail: whistle@protect-advice.org.uk
• Website: www.protect-advice.org.uk

Exceptions

There are no exceptions to this policy statement.
Last Updated: December 2023