Whistleblower Policy

Purpose

At Swift Utility Connections, we are committed to conducting our business with the highest level of integrity, transparency, and ethical standards. We recognize that employees, contractors, subcontractors, consultants, suppliers, and other stakeholders may encounter situations or activities that raise concerns regarding unethical or illegal behavior within the organization. This Whistleblower Policy establishes a clear and confidential process for reporting such concerns and ensures protection for those who raise them, thereby fostering a culture of responsibility and trust.

This policy provides guidance for employees and other stakeholders to report misconduct and assures that all reports will be handled responsibly and transparently, free from fear of retaliation.

Scope

This policy applies to all employees, contractors, subcontractors, consultants, suppliers, and other stakeholders engaged with Swift Utility Connections who may have knowledge of illegal, unethical, or improper conduct within the organization. It covers a wide range of activities, including but not limited to fraud, corruption, bribery, harassment, discrimination, safety violations, or any other unethical or illegal behavior.

Definitions

• Whistleblower: Any employee, contractor, subcontractor, consultant, supplier, or other stakeholder who reports suspected misconduct, illegal activity, or unethical behavior in the workplace.
• Misconduct: Includes, but is not limited to, illegal activity, fraud, corruption, bribery, harassment, discrimination, violation of company policies or procedures, environmental violations, and any other unethical behavior.
• Retaliation: Any form of discrimination, harassment, demotion, suspension, termination, or any other adverse action against an individual for reporting misconduct in good faith.

Reporting Procedure

We encourage all individuals to report concerns regarding misconduct promptly through the following channels:

• Internal Reporting: Employees or other stakeholders are encouraged to report their concerns to their direct supervisor, manager, or another appropriate person within the organization. If the employee feels uncomfortable reporting to their direct supervisor or manager, reports can be made to senior management or other designated representatives within the company.
• Anonymous Reporting: Swift Utility Connections provides a secure and anonymous reporting system for individuals who prefer not to disclose their identity. Reports can be submitted via an internal digital platform, email, or external hotline.
• External Reporting: If an individual feels that the company is not addressing the issue or is involved in the misconduct, concerns may be reported to appropriate external authorities or regulatory bodies, such as: HM Revenue & Customs, The Health and Safety Executive, The Information Commissioner’s Office, The Environment Agency or Scottish Environmental Protection Agency. This list is not exhaustive. If unsure, whistleblowers may seek advice from independent organizations like Public Concern at Work.

Confidentiality

Swift Utility Connections acknowledges the sensitive nature of whistleblowing reports. All concerns will be treated with the utmost confidentiality, and the identity of the whistleblower will be protected unless required otherwise by law or regulation. While every effort will be made to maintain confidentiality, the investigation process may reveal the identity of the whistleblower, and a statement may be required as part of the investigation.

Protection Against Retaliation

We are committed to protecting individuals who report misconduct in good faith. Swift Utility Connections strictly prohibits any form of retaliation against whistleblowers. Retaliation includes, but is not limited to:

• Dismissal, suspension, or demotion
• Harassment, bullying, or discrimination
• Any action that makes the whistleblower feel unsafe or uncomfortable

Retaliation against any whistleblower will be treated seriously, and employees found engaging in retaliatory behavior will be subject to disciplinary action, which may include termination.

Investigation Process

Upon receipt of a whistleblower report, Swift Utility Connections will take the following steps:

1. Acknowledgment: We will acknowledge receipt of the report within 48 hours (unless the report is made anonymously).
2. Investigation: We will conduct a thorough and impartial investigation into the matter. This includes gathering evidence, interviewing relevant parties, and reviewing company policies or practices. Investigations will be handled promptly and without delay.
3. Outcome: Once the investigation is complete, the whistleblower will be informed of the outcome, including any actions taken. Corrective measures may include disciplinary action against employees or contractors, policy amendments, or reports to external authorities.
4. Corrective Actions: If misconduct is confirmed, appropriate corrective actions will be taken. These may include disciplinary action, changes to company procedures, or legal reporting.

Good Faith Reporting

Whistleblowers are expected to act in good faith when raising concerns. Good faith means that the individual reasonably believes that the misconduct has occurred or is occurring. If a report is made in bad faith or with malicious intent, disciplinary action may be taken against the individual who raised the false or malicious claim.

Policy Review and Updates

This policy will be reviewed annually to ensure it remains up-to-date with relevant laws, regulations, and best practices. Any updates or changes to the policy will be communicated to all employees and relevant stakeholders.