Whistle Blowing

Reporting of Bribery and Suspicious Activity: Our Policy on Whistleblowing

If you become aware of any of any actual or suspected breach of this Policy, you must report this to your line manager, or alternatively directly to the managing director (Sandra Cumming), the whistleblowing helpline or the Group External Auditors (Grant Thornton).

 

Processes are in place to ensure that such complaints are investigated and appropriate action is taken. First Impression Labels will not permit retaliation of any kind against any employee for making good faith reports about actual or suspected violation of this Policy.

 

The Group Whistleblowing Policy covers, amongst other matters, the reporting of bribery and suspicious activity. It applies to all Employees of all Group Companies. Group Companies should adapt this Policy as necessary to comply with any local law requirements (for example, if local law requires particular types of whistleblowing concerns to be within the scope of the policy, or if there are

additional requirements as to confidentiality).

 

The Group Whistleblowing Policy is as follows:

  • Whistleblowing reports should be made through existing whistleblowing facilities within the Group.
  • The matters which may be reported under the Whistleblowing Policy include (but are not limited to):

_ concerns about bribery and corruption;

_ concerns about any other criminal activity or failure to comply with legal obligations;

_ concerns about any conduct likely to damage First Impression Labels’ reputation;

_ concerns about accounting, audit or public filing matters;

_ concerns about possible money laundering or sanctions breaches;

_ the deliberate concealment of any of the above matters.

  • Reports made will be handled in confidence and requests for anonymity by reporting individuals will (if possible) be granted.
  • Any Employee who reports an issue in good faith will not suffer any form of retaliation or prejudice as a result of making a report.
  • All material whistleblowing reports must be reported at an appropriate time to the Group General Counsel or Deputy General Counsel. This includes all matters that could have an adverse impact on the reputation of First Impression Labels or the Group Company concerned.

The Whistleblowing Policy should not normally be used for concerns or complaints relating to working conditions or personal employment issues. Employees should direct such concerns to the appropriate Human Resources Department.

 

Please describe your concerns in the form below: