Introduction

Integrity alerts in this Policy refers to the disclosure by any stakeholder (Staff member, Customer, Supplier, Regulator etc.) of malpractice, lapses in integrity as well as illegal acts or omissions at work. This Policy has been established to ensure that all cases of suspected wrongdoing are reported and managed in a timely and appropriate manner.

Davis & Shirtliff (D&S) is committed to the highest standards of openness, integrity and accountability.

Policy Statement

Whoever the company may deal with, and wherever it may operate, it is committed to doing so lawfully, ethically and with integrity. It is the responsibility of each and every stakeholder to ensure that they fulfil this commitment in their day to day relationships with the company. However, from time to time, there may be situations where the right course of action is unclear, or there may be situations where they suspect or know that something is improper, unethical or inappropriate. They have both a legal and moral duty to take appropriate measures to identify such situations and attempt to remedy them.

It is sometimes difficult for people to know whether to speak up about something that concerns them. Often people are reluctant to get involved but this could result in serious consequences for the company and its stakeholders. That is why D&S has put in place this Integrity Alerts Policy – so that stakeholders can talk to someone confidentially and assistance can be offered.

Policy Aims

The aim of this policy is to:

• Ensure all stakeholders feel supported in speaking up in confidence and reporting matters they suspect may involve anything, improper, unethical or inappropriate;
• Encourage all improper, unethical or inappropriate behaviour to be identified and challenged at all levels of the organisation;
• Provide clear procedures for the reporting of such matters;
• Manage all disclosures in a timely, consistent and professional manner; and
• Provide assurance that all disclosures will be taken seriously, treated as confidential and managed without fear of retaliation.

This policy not only covers possible improprieties in matters of financial reporting, but also the following:

• Fraud, misappropriation or misuse of company resources.
• Corruption, bribery or blackmail.
• Criminal offences.
• Failure to comply with legal or regulatory obligations.
• Discriminatory actions.
• Endangering the health and safety of an individual.
• Endangering any element of the environment.
• Lapses in D&S Internal Controls e.g. exploitable gaps within Navision or other areas where the company is exposed to losses.
• Misuse or destruction of company information and records.

Grievance Procedure

Any person reporting should provide evidence to assist in the investigation and arriving at a conclusion. All matters reported will be investigated.

Anyone with a concern or issue that they intend to report may do so by:

1. Contacting This email address is being protected from spambots. You need JavaScript enabled to view it. immediately they become aware of suspected perpetration of fraud either by company staff or by its stakeholders. Emails sent to This email address is being protected from spambots. You need JavaScript enabled to view it. are only received by Mike Eldon, an independent non-executive director who will subsequently direct an investigation on the matter reported. Mike Eldon has made a non-disclosure declaration to ensure the identity of the person reporting is not disclosed without their consent. He may also be directly informed or contacted through This email address is being protected from spambots. You need JavaScript enabled to view it.
2. Reporting anonymously through the D&S Integrity Alerts Reporting Tool (click here), and putting down their issues and clicking on submit. This reporting tool DOES NOT leave a trail of who has made the submission and is hence completely anonymous. The reporter’s concerns will therefore be reported to the Company without revealing their identity.
3. Reporting to an Executive Officer of the company or to the Internal Audit Department.

Anyone who has raised concerns, and chooses to disclose himself/herself will be informed of who is handling the matter, how they can make contact with that person and if there is any further assistance required. The person investigating will give as much feedback as they can without any infringement of the duty of confidence owed to others.

Reporting in Good Faith

If any stakeholder makes an allegation in good faith, but it is not confirmed upon investigation, no action will be taken against them. The company however discourages the making of allegations that are malicious or simply intended to cause anger, irritation or distress.

Anonymous Allegations

This policy encourages individuals to put their name to any disclosures they make. Concerns expressed anonymously are much less credible, but they may be considered at the discretion of the Company.

In exercising this discretion, the factors to be taken into account will include:

• The seriousness of the issues raised.
• The credibility of the concern
• The likelihood of confirming the allegation from attributable sources

Approval and Adoption

This policy, which has been approved and issued by the Executive Management of Davis & Shirtliff, is a statement that improper, unethical or inappropriate behaviour within the organisation is unacceptable and this statement is endorsed and supported at the highest level.

Details

19th Sep 2020