What is Whistleblowing

In this policy 'Whistleblowing' means the reporting by employees of suspected misconduct, illegal acts or failure to act within Commercial Roofing & Cladding Ltd. The aim of this Policy is to encourage employees and others who have serious concerns about any aspect of the Company work to come forward and voice those concerns. Employees are often the first to realise that there may be something seriously wrong within the company.

'Whistleblowing' is viewed by Company as a positive act that can make a valuable contribution to the Company efficiency and long-term success. It is not disloyal to colleagues or the Company to speak up. Commercial Roofing & Cladding Ltd is committed to achieving the highest possible standards of service and the highest possible ethical standards in public life and in all of its practices.

To help achieve these standards it encourages freedom of speech.

If you are considering raising a concern you should read this Policy first. It explains:

The type of issues that can be raised

How the person raising a concern will be protected from victimisation and harassment

How to raise a concern, and what Commercial Roofing & Cladding Ltd will do.

Aim of the Policy and When It Applies

Aims of the Policy

The Policy is designed to ensure that you can raise your concerns about wrongdoing or malpractice within Commercial Roofing & Cladding Ltd without fear of victimisation, subsequent discrimination, disadvantage or dismissal. It is also intended to encourage and enable you to raise serious concerns within Commercial Roofing & Cladding Ltd rather than ignoring a problem or 'blowing the whistle' outside.

This Policy aims to:

• Encourage you to feel confident in raising serious concerns at the earliest opportunity and to question and act upon concerns about practice
• Provide avenues for you to raise those concerns and receive feedback on any action taken
• Ensure that you receive a response to your concerns and that you are aware of how to pursue them if you are not satisfied
• Reassure you that you will be protected from possible reprisals or victimisation if you have made any disclosure in good faith.

Scope of this Policy

This Policy is intended to enable those who become aware of wrongdoing within Commercial Roofing & Cladding Ltd affecting some other person or service, to report their concerns at the earliest opportunity so that they can be properly investigated.

The Whistle Blowing Policy is not intended to replace existing procedures:

• If your concern relates to your own treatment as an employee, you should raise it under the existing grievance or harassment procedures
• If a client has a concern about services provided to him/her, it should be raised as a complaint to Commercial Roofing & Cladding Ltd.

Who Can Raise a Concern Under This Policy

The Policy applies to all:

• Employees of Commercial Roofing & Cladding Ltd
• Employees of contractors and subcontractors working for Commercial Roofing & Cladding Ltd, for example, agency staff, builders and drivers
• Employees of suppliers
• Those providing services under a contract or other agreement with Commercial Roofing & Cladding Ltd in their own premises

What Should Be Reported

Any serious concerns that you have about service provision or the conduct of officers or employees of Commercial Roofing & Cladding Ltd or others acting on behalf of the company that:

• Make you feel uncomfortable in terms of known standards
• Are not in keeping with the company's constitution and policies
• Fall below established standards of practice
• Are improper behaviour

These might relate to:

• Conduct which is an offence or a breach of the law
• Disclosures related to miscarriages of justice
• Racial, sexual, disability or other discrimination
• Health and safety of the public and/or other employees
• Damage to the environment
• Unauthorised use of public funds or other assets
• Possible fraud and corruption
• Neglect or abuse of clients
• Other unethical conduct

This list is not exhaustive.

Protecting the Whistleblower

Your Legal Rights

This policy has been written to take account of the Public Interest Disclosure Act 1998 which protects workers making disclosures about certain matters of concern, when those disclosures are made in accordance with the Act's provisions and in the public interest.

The Act makes it unlawful for the company to dismiss anyone or allow them to be victimised on the basis that they have made an appropriate lawful disclosure in accordance with the Act. Rarely, a case might arise where it is the employee that has participated in the action causing concern. In such a case it is in the employee's interest to come into the open as soon as possible. The company cannot promise not to act against such an employee, but the fact that they came forward may be taken into account.

Harassment or Victimisation

Commercial Roofing & Cladding Ltd is committed to good practice and high standards and to being supportive of you as an employee.

Commercial Roofing & Cladding Ltd recognises that the decision to report a concern can be a difficult one to make. If you honestly and reasonably believe what you are saying is true, you should have nothing to fear because you will be doing your duty to your employer, your colleagues and those for whom you are providing a service.

Commercial Roofing & Cladding Ltd will not tolerate any harassment or victimisation of a whistleblower and will take appropriate action to protect you when you raise a concern in good faith. This will be treated as a serious disciplinary offence.

Support to You

Throughout this process:

• You will be given full support from senior management
• Your concerns will be taken seriously
• Commercial Roofing & Cladding Ltd will do all it can to help you throughout the investigation

If appropriate, Commercial Roofing & Cladding Ltd will consider temporarily re-deploying you for the period of the investigation. For those who are not employees, the company will endeavour to provide appropriate advice and support wherever possible.

Confidentiality

All concerns will be treated in confidence and every effort will be made not to reveal your identity if that is your wish.

If disciplinary or other proceedings follow the investigation, it may not be possible to take action as a result of your disclosure without your help, so you may be asked to come forward as a witness. If you agree to this, you will be offered advice and support.

Anonymous Allegations

This Policy encourages you to put your name to your allegation whenever possible. If you do not tell us who you are it will be much more difficult for us to protect your position or to give you feedback. Concerns expressed anonymously are less powerful but may be considered at the discretion of Commercial Roofing & Cladding Ltd.

Factors considered include:

• The seriousness of the issue raised
• The credibility of the concern
• The likelihood of confirming the allegation from other sources

Untrue Allegations

If you make an allegation in good faith and reasonably believing it to be true, but it is not confirmed by the investigation, Commercial Roofing & Cladding Ltd will recognise your concern and you have nothing to fear. If you make an allegation frivolously, maliciously or for personal gain, appropriate action may be taken.

Raising a Concern

Who Should You Raise Your Concern With

This will depend on the seriousness and sensitivity of the issues involved and who is suspected of the wrongdoing.

You should normally raise concerns with:

• Your Site Supervisor
• The Director

If you are unsure who to contact, the independent charity Protect can advise you. They offer a free and confidential helpline on 020 3117 2520.

How to Raise a Concern

You may raise your concern by telephone, in person or in writing. The earlier you express your concern, the easier it is to take action.

You will need to provide:

• The nature of your concern and why you believe it to be true
• The background and history of the concern

You are not expected to prove beyond doubt the truth of your suspicion, but you must demonstrate genuine concern and reasonable grounds. You may wish to discuss your concern with a colleague first. You may invite a union representative, professional association representative or friend to be present during any meetings.

What Commercial Roofing & Cladding Ltd Will Do

Commercial Roofing & Cladding Ltd will respond to your concerns as quickly as possible. Testing your concerns is not the same as accepting or rejecting them.

Initial enquiries will be made to decide whether an investigation is appropriate and what form it should take. Investigations may need to be carried out confidentially. In certain cases, such as allegations of ill treatment, suspension may be considered immediately.

Where appropriate, matters raised may:

• Be investigated internally
• Be referred to the police
• Be referred to the external auditor
• Be referred through established child protection or abuse procedures
• Form the subject of an independent inquiry
• Within ten working days of a concern being raised, the investigator will write to you:
• Acknowledging the concern
• Indicating how the company proposes to deal with the matter
• Providing information on support mechanisms
• Confirming whether further investigations will take place
• You may be interviewed to ensure your disclosure is fully understood. Meetings can be arranged away from your workplace and you may bring a representative or friend.

You will be kept informed of progress unless legal reasons prevent this.

Responsible Officer

The Monitoring Officer has overall responsibility for the maintenance and operation of this Policy.

How the Matter Can Be Taken Further

If you are not satisfied with the action taken and feel it is right to take the matter outside the company, prescribed contacts include:

• The police
• Other relevant bodies prescribed by legislation

The Monitoring Officer can advise you who to contact. You should ensure disclosures are made only to prescribed contacts to remain protected under the Public Interest Disclosure Act.

You should not disclose confidential information except to prescribed contacts. This Policy does not prevent you from taking legal advice.

Review of the Policy

Commercial Roofing & Cladding Ltd will review this Policy annually.

Corporate Recording and Monitoring

The Monitoring Officer will maintain a corporate register containing all concerns raised. Officers investigating concerns must provide sufficient details for the register.

The Monitoring Officer will review the register and produce an annual report summarising concerns, departments involved, posts related (if not confidential) and lessons learned. No employee names will be included.

This ensures:

• The company learns from mistakes
• Consistency of approach across departments

This Policy will be reviewed regularly to ensure effectiveness and alignment with expectations.

Last review: 9th October 2026