1. ABOUT THIS POLICY

1.1 Matthew Algie are committed to conducting our business with honesty and integrity and we expect all staff to maintain high standards. Any suspected wrongdoing should be reported as soon as possible.

1.2 This policy covers all employees, officers, consultants, contractors, volunteers, interns, casual workers, and agency workers.

1.3 This policy does not form part of any employee's contract of employment, and we may amend it at any time.

2. WHAT IS WHISTLEBLOWING?

Whistleblowing is the reporting of suspected wrongdoing or dangers at work. This may include bribery, fraud or other criminal activity, miscarriages of justice, health and safety risks, damage to the environment, product safety, integrity, quality and labelling issues and any breach of legal or professional obligations.

A personal concern, for example a grievance around an employee’s contract of employment, would not be regarded as a whistleblowing concern and would be more appropriately processed through our Grievance Procedure.

Further information can be found via these links:
UK: https://www.gov.uk/whistleblowing
Ireland: http://www.citizensinformation.ie/en/employment/enforcement_and_redress/protection_for_whistleblowers.html

3. HOW TO RAISE A CONCERN INTERNALLY

3.1 Concerns may be raised with the direct reporting manager, either verbally or in writing.

3.2 We hope that in many cases concerns will be able to be raised with the direct reporting manager. However, where there is preference not to raise it with the direct reporting manager for any reason, concerns should be raised to the Managing Director or a member of the HR team.

4. INTERNAL INVESTIGATION OF CONCERNS

4.1 We will arrange a meeting with the employee as soon as possible to discuss their concerns. They may bring a colleague or union representative to any meetings under this policy. The companion must respect the confidentiality of the disclosure and any subsequent investigation.

4.2 Having met with the employee and clarified that the matter is appropriate to this procedure, we will carry out an assessment to examine what actions are required to deal with the concerns.

4.3 It is important to us that the employee feels assured that a disclosure made under this policy is taken seriously and that they are kept informed of steps being taken in response. In this regard, we undertake to communicate as follows:

• We will acknowledge receipt of the disclosure and arrange to meet with the employee as outlined above.
• We will inform the employee of how we propose to investigate the matter and keep them informed of actions, where possible, including the outcome of any investigation, and, if applicable, why no further investigation will take place. However, confidentiality and legal considerations may prevent us from giving specific details.
• We will inform the employee of the likely timescales for each step, and in any event, commit to dealing with the matter as quickly as practicable.

5. HOW TO RAISE A CONCERN EXTERNALLY

5.1 If the employee does not feel it appropriate to raise their concerns internally, they may report a concern to our whistleblowing hotline, BKMS.

5.2 BKMS is an independent whistleblowing service appointed by our Company, maxingvest ag. Any and all concerns can be raised via their portal which can be found here.

6. EXTERNAL INVESTIGATION OF CONCERNS

6.1 BKMS will share relevant reports with the Compliance Committee within maxingvest ag. The Compliance Committee is an internal committee made up of representatives of maxingvest ag, Tchibo Coffee Service GmbH, Tchibo GmbH and the Chairman of the Works Council.

6.2 The Compliance Committee will liaise with the UK and Ireland Group, as well as any other relevant parties such as the Data Protection team, to investigate any raised concerns.

6.3 Where necessary, the UK and Ireland Group may contact external authorities to support any investigation or disclose any illegal action.

7. CONFIDENTIALITY

7.1 So long as whistleblowers do not enter any identifying data points into their disclosures, their identity will remain unknown and confidential.

7.2 Whistleblowers may provide contact details, including an anonymous email address, to allow investigators to request further information or confirm completion of the investigation.

8. EXTERNAL DISCLOSURES

8.1 The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying wrongdoing in the workplace. In most cases, the employee should not find it necessary to alert anyone externally, other than BKMS.

8.2 The law recognises that in some circumstances it may be appropriate for the employee to report concerns to an external body such as a regulator. We strongly encourage them to seek advice before reporting a concern externally. However, if after doing so the employee still feels the matter should be reported externally, a list of prescribed bodies can be accessed from the links below.

Reporting a food crime can be done anonymously via 0800 0287926
https://www.foodstandards.gov.scot/consumers/food-safety

UK: https://www.gov.uk/government/publications/blowing-the-whistle-list-of-prescribed-people-and-bodies--2
Ireland: http://www.irishstatutebook.ie/eli/2014/si/339/made/en/print
Amended by: http://www.irishstatutebook.ie/eli/2015/si/448/made/en/print

9. PROTECTION AND SUPPORT FOR WHISTLEBLOWERS

9.1 We aim to encourage openness and will support whistleblowers who raise genuine concerns under this policy, even if they turn out to be mistaken.

9.2 Whistleblowers must not suffer any detrimental treatment as a result of raising a genuine concern. If they believe they have experienced such treatment, they should inform their direct reporting manager immediately. If unresolved, they should raise it formally using our Grievance Procedure.

9.3 The company must not threaten or retaliate against whistleblowers in any way. Individuals engaging in such conduct may be subject to disciplinary action and, in some cases, personal liability in an employment tribunal.

9.4 If we conclude that a whistleblower has made false allegations maliciously or for personal gain, disciplinary action may be taken.

POLICY ENDORSEMENT

Endorsed: Paul Chadderton – Managing Director
Date: 03/7/2023

Endorsed: Nikki Herridge – Head of Human Resources
Date: 03/7/2023