Whistleblowing Policy

Scope

We recognise that colleagues may not always feel comfortable about discussing their concerns with others in the Company, especially if they believe that the business itself is responsible for the wrongdoing.

The aim of this policy is to ensure that colleagues are confident that they can raise any concern about our business activities in the knowledge that it will be taken seriously, and that no action will be taken against them.

This policy applies to all directly employed colleagues of the Company and its subsidiaries.

Responsibilities

Colleagues

All colleagues have a responsibility to work within the confines of all normal operating practices and Company policies and procedures.

All colleagues have the responsibility to use this Whistleblowing policy as appropriate, ensuring that any breach is reported at the correct time and in the correct manner, wherever possible.

Managers

Line Managers have the responsibility of responding to any member of their team or any other colleague who raises a whistleblowing complaint to them, seeking the appropriate support from other departments (HSEQ, HR, etc) as required.

Line Managers are responsible for ordering and displaying the Whistleblowing awareness posters within work premises. Posters can be ordered online and posted out the work premises, the information for the ordering process is found on Interaction below the Whistleblowing policy.

HSEQ Department

The wider HSEQ department are responsible for ensuring the Policy is followed and applied fairly. The HSEQ department will provide impartial advice and guidance to all parties involved in the application of the Whistleblowing Policy.

People Team

The Group Board has appointed Charlotte Bennett, People Director as the Company’s Designated Whistleblowing Officer (DWO).

The People team are responsible for ensuring the Policy is followed and applied fairly. The People team will provide impartial advice and guidance to all parties involved in the application of the Whistleblowing Policy.

The People team will retain copies of all documentation gathered or produced as part of the process in line with GDPR guidelines. They are also responsible for monitoring and updating relevant policies and procedures.

Process

Qualifying Disclosures

Certain disclosures are prescribed by law as “qualifying disclosures”. A “qualifying disclosure” means a disclosure of information that the individual genuinely and reasonably believes is in the public interest and shows that the Company has committed a “relevant failure” by:

• committing a criminal offence
• failing to comply with a legal obligation
• a miscarriage of justice
• endangering the health and safety of an individual
• environmental damage or
• concealing any information relating to the above.

These acts can be in the past, present or future, so that, for example, a disclosure qualifies if it relates to environmental damage that has happened, is happening, or is likely to happen. The Company will take any concerns that you may raise relating to the above matters very seriously.

Colleagues must reasonably believe that the disclosure is “in the public interest”. We encourage you to use the procedure to raise any such concerns.

Should the concern not meet the requirement to be a qualifying disclosure, you should raise this under the Company’s Grievance Policy instead. Where a concern is raised under the Whistleblowing Policy where it is not appropriate to do so, i.e. it relates to a personal grievance, the receiving manager will confirm that the matter will be addressed under the Grievance Policy instead.

Procedure

In the first instance you should report any concerns you may have to your line manager or Charlotte Bennett (Designated Whistleblowing Officer), where the concern relates to your line manager, or it is not appropriate to make the report to your line manager.

All concerns reported will be treated in the utmost confidence. You may submit your concerns in any format, but you may be asked to confirm any verbal concerns in writing or to confirm a written record of a verbal report.

Charlotte Bennett can be emailed to our confidential email address shown below:

whistleblowing@sunbeltrentals.co.uk

Anonymous Disclosures

We recognise that disclosures made under this policy may involve highly confidential and sensitive matters and that colleagues may prefer to make an anonymous disclosure.

Anonymous disclosures can therefore be made using the Navex Global Whistleblowing on the below details:

Phone No UK (Inc Northern Ireland) 0800 031 8508

Eire 180 045 8508

It is important to emphasise that the Company cannot guarantee to fully investigate all anonymous allegations. Proper investigation may prove impossible if the investigator cannot obtain further information from you, give you feedback, or ascertain whether your disclosure was made in good faith. For this reason, it is always preferable for whistleblowers to reveal their identity and measures can be taken to preserve confidentiality if appropriate.

Following receipt of a disclosure made under this policy, an investigation meeting will be held with the individual, if deemed appropriate. The purpose of this meeting is to gather as much information as possible from the colleague regarding their concerns, including whether they have any supporting evidence or can identify any witnesses.

After this meeting, the investigating manager will commence a full investigation into the concerns raised. The investigation will aim to gather all relevant information including relevant documentary evidence or witness statements.

Once the investigation is complete, the investigation manager will write to the colleague confirming the outcome.

If the colleague is not satisfied with the explanation or outcome, they may raise the matter with the appropriate official organisation or regulatory body. Alternatively, individuals may raise a formal complaint under the Company’s Grievance Policy.

Formal Action

Should formal action be required as a result of any disclosure made under this policy, this action will be carried out in accordance with the applicable internal policy. Any potential sanctions imposed will be fair and reasonable in line with the relevant policy.

Protection Against Detrimental Treatment

All individuals who raise matters of concern under this policy are protected against detrimental treatment, up to and including dismissal, because they have made a disclosure.

Bullying, harassment or any other detrimental treatment afforded to a colleague who has made a qualifying disclosure is unacceptable. Anyone found to have acted in such a manner will be subject to being managed under the Company’s Disciplinary Policy.

Phil Parker

Chief Executive Officer - Sunbelt Rentals Ltd

March 2025