How to report a Code breach

If you have a concern or you think that a breach of The Code might be taking place, it is important that you speak up about it.

Speaking up early could protect you from serious legal consequences; avoid damage to the company’s reputation and even save someone’s life. We will never penalise anyone for reporting a breach in good faith, even if his or her suspicions prove to be unfounded.

What to do

If you are aware of a breach of The Code, or if you are suspicious that a breach is taking place, you must report it. There are a number of different ways you can raise a concern or receive help and advice. Choose whichever route you feel comfortable with, or which best suits the particular situation..

i. Report the issue to your line manager or supervisor

ii. Any Director or above throughout the

Keltbray Group

iii.Report the issue to our Group Legal Counsel or to the Group People Director

iv. Report the issue by emailing 'concerns@ keltbray.com', our confidential reporting service. This is a securely administered service, ensuring impartiality and confidentiality

All reported breaches will be investigated appropriately and with due consideration of a person’s wish for anonymity. Depending on the circumstances, the results of an investigation may include disciplinary action up to and including dismissal. Ultimately, findings will be reported to our Group Main and Executive Boards. If a crime is found to have been committed, the investigation team will contact the police who may initiate legal proceedings. It should also be noted that the same levels of disciplinary action can also result from an individual reporting a potential Code breach in bad faith, as an act of prejudice, malice or any other wrongful motivation.

Report the issue to...

i. Your line manager or supervisor

ii. Any Director or above throughout the Keltbray Group

iii. 0ur Group Legal Counsel or to the Group People Director

iv. By emailing... concerns@keltbray.com