Whistleblowing Policy
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 support this, we have developed this Whistleblowing Policy and implemented the SpeakUp platform, allowing for confidential reporting of concerns.
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 SpeakUp platform offers an additional layer of protection and confidentiality for individuals making disclosures in good faith.
Individuals making a disclosure in good faith and with reasonable belief that the information tends to show malpractice or impropriety are protected under this policy. Ekco is committed to investigating all concerns raised responsibly, professionally, and without prejudice.
Using SpeakUp
In most cases, employees should feel comfortable raising any concerns directly with their line manager. However, if they prefer, concerns can be raised via the SpeakUp platform, either anonymously or confidentially. While anonymity is available, Ekco encourages individuals to provide their identity to facilitate thorough investigations, though confidentiality will always be maintained wherever possible. SpeakUp allows for direct, secure submission of reports that can be monitored and managed without revealing the reporter’s identity.
Raising Concerns
If the individual feels that their concern has not been appropriately addressed, they can escalate the matter directly through SpeakUp or by contacting the Director of People Operations. All concerns raised will be handled promptly and professionally. Ekco is committed to ensuring that each report is thoroughly investigated, and appropriate actions are taken to address the issues raised. Feedback will be provided to the individual where possible, respecting confidentiality and the nature of the concern.
Confidentiality
SpeakUp provides the option for individuals to report concerns either anonymously or confidentially, according to their preference. Ekco recognises the importance of protecting the identity of those who raise concerns and is committed to ensuring that all reports are treated with the utmost discretion.
Whether a report is submitted anonymously or not, every effort will be made to maintain the confidentiality of the complainant. The identity of the individual will only be disclosed if necessary, such as when it is essential for conducting a thorough investigation, required by law, or where the individual’s consent has been obtained. In cases where anonymity may limit the scope of the investigation, Ekco will still take appropriate action based on the information available.
We understand that maintaining confidentiality is crucial to building trust in the whistleblowing process, and Ekco is committed to ensuring that those raising concerns are protected from any form of retaliation or disadvantage.
Untrue Allegations
If an individual makes a disclosure in good faith and it is not confirmed by subsequent investigation, no action will be taken against the individual. However, if an individual knowingly makes malicious or vexatious allegations without reasonable grounds, this may be addressed through appropriate measures in line with company policies.
External Disclosures
The purpose of this policy is to provide an internal mechanism for reporting, investigating, and remedying wrongdoing within Ekco. In most cases, reporting externally should not be necessary. However, the law recognises that in some situations, it may be appropriate to report concerns to an external body, such as a regulator.
Before taking this step, we encourage individuals to seek advice, and they may still use the SpeakUp platform to obtain guidance and support.
Making a Disclosure
There are a number of ways to report a breach of suspected violation of our policies, procedures, or applicable law:
• Always feel free to discuss the issue with your line manager.
• If you are not comfortable discussing it with your line manager, you can discuss the issue with your
People Team business partner.
• You can also submit your report through SpeakUp, using the following procedures:
o Using the SpeakUp app
o Using the SpeakUp portal
o Download the SpeakUp app, which is available for iOS and Android
o Leave a report.
Reporting a Concern Anonymously
To report a concern anonymously, employees can use the SpeakUp Platform
https://ekco.speakup.report/ekco). The platform allows for secure and confidential submission of reports without revealing the reporter’s identity. Here are the steps to report a concern anonymously:
• Visit the SpeakUp Platform at https://ekco.speakup.report/ekco.
• Follow the instructions to submit your report.
• Ensure that you do not include any identifying information if you wish to remain anonymous.
• Your report will be securely transmitted and managed without revealing your identity.
I Spoke Up. Now What?
When you submit a report, the SpeakUp Office will acknowledge receipt within seven days. Your report will be evaluated, and the appropriate action will be determined. You may be asked follow-up questions. Feedback will be provided within three months, but details of the investigation may not always be shared due to confidentiality and legal reasons. All parties involved are entitled to confidentiality, and you must keep the matter confidential if you participate in or learn about an investigation.
Not all issues will lead to a formal investigation; sometimes, other actions like mediation are more appropriate. Insufficient information may also prevent an investigation.
Protecting You, Speaking Up
Your right to speak up is protected. Key principles include:
• Confidentiality: All issues are treated confidentially and shared only on a need-to-know basis. Your identity will not be disclosed.
• Solid Investigation Procedures: The SpeakUp Office ensures precise fact-finding.
• Anonymous Reporting: Use the SpeakUp Line for anonymous reporting. The SpeakUp Office will anonymise information to protect your identity.
• Privacy: Personal data is safeguarded and processed in line with our privacy policy.
• Non-Retaliation: Speaking up is encouraged and protected. Any retaliation will lead to disciplinary measures.
Protecting the Accused
The accused are protected under the presumption of innocence. Key principles include:
• Confidentiality: Issues are treated confidentially and shared only on a need-to-know basis.
• Solid Investigation Procedures: The SpeakUp Office ensures precise fact-finding.
• Information Rights: The accused will be notified of the investigation unless it risks evidence destruction or impedes the investigation.
• Right to Defend and Appeal: The accused can respond to accusations and comment on findings.
They have the right to appeal.
The SpeakUp Office
The SpeakUp Office, consisting of trained professionals, executes the SpeakUp policy and handles reports. The policy is owned by both our People Operations and our Governance, Risk, and Compliance leaders. The SpeakUp Office reports to the group President. Members are protected against retaliation.
Not Satisfied with the SpeakUp Process
If you are not satisfied with the handling or outcome of your report, contact the SpeakUp Office or use the SpeakUp Line.
Contact Details & Useful Link
Applicable Legislation
This policy and the Ekco approach to whistleblowing has been designed in accordance with the following legislation:
• Ireland – Protected Disclosures (Amendment) Act 2022
• United Kingdom – Public Interest Disclosure Act 1998 (PIDA)
• Netherlands – Wet bescherming klokkenluiders (Whistleblower Protection Act) 2023
• South Africa – Protected Disclosures Act 2000
• Malaysia – Whistleblower Protection Act 2010
Exceptions
There are no exceptions to this policy statement.
Last Updated: November 2024
