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Speak Up Policy

B38 Group wants to know about any breach or potential breach of our business principles, policies and standards, unlawful conduct, financial malpractice or dangers to the public, the environment, or to anyone working at B38 Group, that may be occurring despite our rigorous compliance procedures.

B38 Group personnel therefore have a duty to Speak Up promptly if they have a reasonable belief that there has been a breach or potential breach of our Business Principles, Policies and Standards or any other misconduct. If an issue is raised internally first, and acted upon, it is likely to reduce any damage that may otherwise occur. Reporting of issues will detect and possibly deter any further wrongdoing.

Possible breaches of B38 Group’s Business Principles and Policies include:

• Ethics and compliance issues, such as financial mis-reporting, insider trading, bribes or conflicts of interest;
• Employee relations and human resources issues, such as harassment or discrimination;
• Loss prevention and asset protection issues, such as criminal activity (for example fraud, threats and violence, alcohol/drug abuse or internal theft) and
• Health and safety, such as taking unnecessary risks, not following mandatory Standards or false reporting.

B38 Group will not tolerate harassment or retaliation of any kind against anyone who seeks advice or raises a genuine concern about a breach or potential breach. Any personnel who subject a colleague to such treatment will face serious consequences such as disciplinary action or contract termination. They may also expose themselves and B38 Group to legal liability.