Whistleblowing Policy

Scope

We recognise that colleagues may not always feel comfortable about discussing their concerns with others in the Company, especially if they believe that the business itself is responsible for the wrongdoing.

The aim of this Policy is to ensure that colleagues are confident that they can raise any concern about our business activities in the knowledge that it will be taken seriously, and that no action will be taken against them.

This Policy applies to all employees of the Company and its subsidiaries, as well as third parties, including customers, suppliers and member of the public.

Responsibilities

Colleagues

All colleagues have a responsibility to work within the confines of all normal operating practices and Company policies and procedures. Policies and procedures can be accessed via the Company intranet or via line managers.

All colleagues have the responsibility to use this Whistleblowing Policy as appropriate, ensuring that any breach or suspected breach is reported as soon as is possible.

Managers

Line managers have the responsibility for responding to any employee who raises a whistleblowing concern with them, seeking appropriate support from other departments as required.

HSEQ and HR Departments

Mark Keily, HSEQ Director, has been appointed as the Company’s Designated Whistleblowing Officer (DWO).

The HSEQ and HR departments will provide impartial advice and guidance to all parties involved in the application of the Whistleblowing Policy (which department will support the process will depend on the nature of the complaint raised).

The HR department will retain copies of all documentation gathered or produced as part of the process in line with GDPR guidelines.

Process

Qualifying Disclosures

Certain disclosures are prescribed by law as “qualifying disclosures”. A “qualifying disclosure” means a disclosure of information that the individual genuinely and reasonably believes is in the public interest and shows that the Company has committed a “relevant failure” by:

• committing a criminal offence
• failing to comply with a legal obligation
• a miscarriage of justice
• endangering the health and safety of an individual
• environmental damage or
• concealing any information relating to the above.

These acts or omissions can be in the past, present or future, so that, for example, a disclosure qualifies if it relates to environmental damage that has happened, is happening, or is likely to happen. The Company will take any concerns that you raise relating to the above matters very seriously.

Colleagues must reasonably believe that the disclosure is “in the public interest”. We encourage you to use the procedure to raise any such concerns.

Should the concern not meet the requirement to be a qualifying disclosure, you should raise this under the Company’s Grievance Policy or Near Miss Procedure instead (both documents can be found on the Company intranet). Where a concern is raised under the Whistleblowing Policy where it is not appropriate to do so, i.e. it relates to a personal grievance, the receiving manager will confirm that the matter will be addressed under the Grievance Policy instead.

Procedure

In the first instance you should report any concerns you may have to your line manager or Mark Keily (Designated Whistleblowing Officer), where the concern relates to your line manager or it is not appropriate to make the report to your line manager.

All concerns reported will be treated in the utmost confidence. You may submit your concerns in any format, but you may be asked to confirm any verbal concerns in writing or to confirm a written record of a verbal report.

Mark Keily can be emailed on whistleblowing@sunbeltrentals.co.uk and his telephone number is 07815650763.

Following receipt of a disclosure made under this Policy, an investigation meeting will be held with the individual, if deemed appropriate. The purpose of this meeting is to gather as much information as possible from the colleague regarding their concerns, including whether they have any supporting evidence or can identify any witnesses.

After this meeting, the investigating manager will commence a full investigation into the concerns raised. The investigation will aim to gather all relevant information including relevant documentary evidence or witness statements.

Once the investigation is complete, the investigation manager will write to the colleague confirming any relevant outcomes, in line with the Company GDPR Policy.

If the colleague is not satisfied with the explanation or outcome, they may raise the matter with the appropriate official organisation or regulatory body. Alternatively, individuals may raise a formal complaint under the Company’s Grievance Policy.

Anonymous Disclosures

We recognise that disclosures made under this Policy may involve highly confidential and sensitive matters and that colleagues may prefer to make an anonymous disclosure.

Anonymous disclosures can therefore be made using the Sunbelt Rentals AlertLine facility by calling 0844 892 4413.

It is important to emphasise that the Company cannot guarantee to fully investigate all anonymous allegations. Full investigation may prove impossible if the investigator cannot obtain further information from you, give you feedback, or ascertain whether your disclosure was made in good faith. For this reason, it is always preferable for whistleblowers to reveal their identity and measures can be taken to preserve confidentiality if appropriate.

Third Party Disclosures

Anyone who is not employed directly by the Company but has a qualifying disclosure that they wish to raise under this Policy should follow the process as outlined above, by either contacting the DWO or the Alertline facility.

By making a disclosure in this manner, the third party will be kept updated as appropriate and in line with GDPR guidelines.

Formal Action

Should formal action be required as a result of any disclosure made under this Policy, this action will be carried out in accordance with the applicable internal Policy. Any potential sanctions imposed will be fair and reasonable in line with the relevant Policy.

Protection Against Detrimental Treatment

All individuals who raise matters of concern under this Policy are protected against detrimental treatment, up to and including dismissal, because they have made a disclosure.

Bullying, harassment or any other detrimental treatment afforded to a colleague who has made a qualifying disclosure is unacceptable. Anyone found to have acted in such a manner will be subject to being managed under the Company’s Disciplinary Policy.

Andy Wright

Chief Executive Officer - Sunbelt Rentals Ltd

June 2021