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Whistleblowing

1. Aim

Chesnara Plc and its divisions (together ‘the Company’) are committed to ensuring transparency, accuracy and accountability across all its operations.  As part of this commitment, we want to ensure that there are policies and processes in place to provide our people with the ability to raise concerns and to do so confidentially and without retaliation.

Such concerns may relate to, for example, colleagues taking or soliciting bribes, financial fraud, or criminal activity. The action of raising these concerns in a formal manner is called whistleblowing.

This page provides an overview of the key elements of our whistleblowing practices and procedures.

2. Summary

At Chesnara, we strongly encourage all employees, suppliers, customers, and other contracted parties experiencing concerns about any aspect of the Company’s work to come forward and report them. Our policies make sure anyone can voice concerns without fear of reprisal, and we strive to maintain effective mechanisms throughout our group to ensure any concerns are appropriately remedied.

Each of our divisions make use of stringent policies and procedures to ensure that the highest standards are met across the group. These policies are made in accordance with the relevant laws and regulations of the respective jurisdictions and are available in local languages. Policies are reviewed on an annual basis and any changes made are communicated to individuals throughout the Company.

3. Scope

3.1 Who do our policies apply to?

The policies we have in place have been adopted by Chesnara Plc and the divisional boards. They apply to directors, staff, outsourced service providers (OSPs), contractors and consultants in relation to all activities undertaken by, or on behalf, of the Company. Our whistleblowing process is also available to third parties, including contractors and suppliers,, who can report externally using the relevant authorities.

Communication is key to our operations. As such, we make certain that our policies are communicated and made easily accessible to everyone involved in the business to ensure their awareness of - and commitment to- them.

3.2 Which concerns are relevant to the whistleblowing procedure?

The effective operation of any of our policies relies on proper use by individuals. It is therefore important to us that individuals remain informed of the nature of concerns which are relevant to whistleblowing protection.

The Company believes that, provided any allegation is made lawfully and in the public interest, individuals should be able to raise legitimate concerns. The Company does not operate a closed list of relevant concerns – instead, the appropriateness of a situation as coming within whistleblowing protections is assessed on a case-by-case basis and in accordance with our internal procedures. Relevant concerns may include, for example: colleagues offering, taking or soliciting bribes; financial fraud or mismanagement; unauthorised disclosure of confidential information; criminal activity; miscarriages of justice; or negligence in fulfilling duties.

Within the UK, this means that disclosures made may fall under those “protected disclosures” as defined in the Public Interest Disclosure Act 1998; however, they are not required to.

4. Ownership

The policy has been approved by the Board who retain full collective responsibility for it, with the Group Chief Risk Officer acting as policy owner.  The policy sponsor is the Chair of the Group Audit & Risk Committee who is nominated to be the Whistleblowing Champion.

5. Non-retaliation

We recognise the difficulty in raising concerns about business practices or colleagues, which is why we have taken steps to ensure any person that raises concerns remains fully protected.

The Company commits to ensuring that individuals who raise concerns in good faith are provided protection from retaliation, harassment, or unfair treatment. Where appropriate, employment-related specific measures are undertaken to safeguard whistleblowers from victimisation.

Any potential instances of victimisation are taken seriously and may be subject to disciplinary action. Victimisation may include (but is not limited to) dismissal or termination, demotion, negative performance review, or exclusion from work projects and/or social events. Where someone feels that they have been subject to retaliation or unfair treatment as a result of their whistleblowing, we recommend that they contact the relevant HR department.

If someone is found to have abused the process through making allegations other than in good faith; repeating unfounded allegations; making unsubstantiated allegations; making malicious allegations etc then they themselves may be subject to disciplinary action. They may, as a result, be subject to legal proceedings or prosecution in accordance with the relevant laws.

6. Confidentiality and Anonymous Reporting

As a company dedicated to ensuring an individual’s protection from victimisation, we provide the option for individuals to request that their identity remain confidential. The Company will take all reasonable steps to maintain the confidentiality of the whistleblower when requested unless required by the law of the relevant jurisdiction to break that confidentiality. These measures seek to ensure that individuals feel comfortable raising a whistleblowing concern and reduce improper treatment being received by those outside of the Company’s control.

We understand the difficulty in coming forward with a whistleblowing concern, which is why we also offer the ability to report the concern anonymously. Individuals are able to report anonymously via telephone line or an alternative email address. In certain circumstances, when a report has been made anonymously, action taken may be limited if all information needed has not been provided.

7. Raising a concern

7.1 Internal

We encourage that individuals who wish to raise a concern do so with their immediate manager if that person is thought not to be involved or implicated in any way. However, we recognise that this might not always be the case. As such, appropriate alternative contact points are featured within the policy documents of our respective divisions. Within the UK, the Whistleblowing Champion is also available to be contacted. These communication lines are made clear to individuals throughout their time with the company, enabling them to easily raise a concern.

7.2 External

While our policies are intended to provide individuals with an avenue to raise any concerns they have with the organisation in the first instance, in exceptional circumstances this may not be possible. An individual may feel it necessary to report the matter externally if they believe the information disclosed and any allegations contained in it are substantially true any not made for personal gain.

Any individual or third party who chooses to raise a concern externally is able to do so via contacting the relevant authority. A non-exhaustive list of which is included within our policy. Within the UK, a list of relevant bodies can also be found at https://www.bankofengland.co.uk/prudential-regulation/whistleblowing-and-the-pra or https://www.fca.org.uk/firms/whistleblowing.

8. Data confidentiality

We take the protection of personal data seriously. Any information held by us relating to the whistleblowing claim, including its raising, investigation, or outcome, will be treated in accordance with our internal data protection and privacy policies.

9. Investigation processes

Any concern raised with the Company in line with our policies will be treated seriously and sensitively. We maintain a vigorous investigation process ensuring that concerns raised are dealt effectively, efficiently and to the highest standards.

9.1 Internal process

When a concern is raised internally, a member of our senior management team will conduct appropriate, prompt and independent investigations into the matter. Normally, allegations made will be subject to a preliminary investigation. Matters relating to financial irregularity are normally led by Internal Audit whereas other matters are led by a person or persons nominated by the individual to whom the allegation is made. In order to ensure an independent and fair investigation, those who may be required to make a final decision on the matter or any person who may have a conflict of interest will not conduct the investigation.

While the investigation procedures are clearly laid out in our internal policies – we strive to ensure that no errors are made during an investigation process. As such, prior to any investigation, its leader will consult with the HR function to ensure that all appropriate procedures are followed in respect of individuals under investigation. If the preliminary investigation finds that there is substance to the complaint, the matter may be considered under the appropriate stage of the disciplinary procedures and may be the subject of a formal investigation and/or referred to the police and/or regulatory bodies.

If an allegation is dismissed summarily without investigation, the person making it will be given the opportunity to restate it to a more senior individual in the organisation.

9.2 Outcome of investigation

The outcome of any investigations will be reported to the relevant Audit and Risk Committee. Generally, the persons who the allegation has been made against will be told of the allegation and supporting evidence. They will be provided with the opportunity to comment before the preliminary investigation is concluded and its findings published; will be informed of the outcome of the investigation; and will be entitled to receive a copy of the report if disciplinary action is to be taken.

Individuals who make an allegation will be informed of the general outcome of any investigations and of the senior manager and/or committee to whom the report is issued but they will not be automatically entitled to receive a copy of the report or information on the detailed findings therein.

9.3 Record keeping

We maintain full records of all reports and subsequent investigations for at least 6 years following a report being made.

10. Reporting

In accordance with our obligations as a financial entity, we will continue to adhere to the reporting requirements of the relevant jurisdiction. Within the UK the Whistleblowing Champion will report annually to the boards. The report includes the number of cases, an assessment of the effectiveness of the whistleblowing systems and controls as well as details of any actions raised as a result of whistleblowing. Disclosure of the number of whistleblowing cases forms part of our annual report, which can be found on our website. The relevant regulators are informed whenever necessary including the Prudential Regulation Authority receiving the annual report upon request.

11. Policy review

We are committed to maintaining a high standard of whistleblowing protection across the group, which is why our Group Chief Risk Officer along with local risk and compliance teams continue to monitor the effectiveness of our whistleblowing policy and report to the boards on its suitability, adequacy, and effectiveness. In addition, this policy, along with our other internal control systems and procedures, are subject to audits as agreed in the Annual Audit Plan, to provide assurance that they are effective in countering fraud.

We strive to uphold effective whistleblowing procedures – and our Group Chief Risk Officer works to annually review the contents of our policy and its effectiveness, which is then presented to the Chair of the Group Audit and Risk Committee. Any appropriate revisions are requested to the Chair as Whistleblowing Champion and Policy Sponsor. In line with our internal procedures, the Chair of the Group Audit and Risk Committee will propose material change in the policy to the board and the Group CEO will approve non-material change.

At Chesnara, we are committed to maintaining high standards of practice throughout all our operations. Accordingly, we conduct an annual review of the effectiveness of our whistleblowing policies and systems of control. The review covers compliance with whistleblowing policies and reporting issues related to them following obligations under the provisions of the UK Corporate Governance Code. The review, conducted by the Audit and Risk Committee following reporting from divisional practices, is presented to the board for approval, who confirm reasonable assurance that the Company’s whistleblowing policies and related control systems have both operated effectively.

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