Whistleblowing Policy

What this policy is for

We recognise that employees 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 employees 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.

The Law

Whistleblowing is the disclosure of information by a worker, which relates to some danger, fraud or other illegal or unethical conduct in the workplace. The Employment Rights Act 1996 as amended by the Public Interest Disclosure Act 1998 governs the making of disclosures concerning workplace activities and is intended to protect workers who blow the whistle on bad practice from being subjected to any detriment or unfairly dismissed as a result.

Whistleblowing Procedure

Employees are encouraged to use the procedure set out below if they have a concern about any of the following:

The employee does not have to be able to prove the allegations, but should have a reasonable and genuine belief that the information being disclosed is true: some allegations may prove to be unfounded, but we would prefer the issue or concern to be raised, rather than run the risk of not detecting a problem early on.

This policy is distinct from the Company’s Grievance Procedure and Bullying and Harassment Procedure. If you have a complaint relating to your personal circumstances in the workplace then you should use the Grievance or Bullying and Harassment Procedure as appropriate.

Reporting a Concern Under the Procedure

Wherever possible, the employee should discuss the matter with his/her line manager in the first instance. However, should he/she prefer (perhaps because the manager is unavailable, or indeed might be the cause of the concern), then the matter should be reported either orally or in writing to the QHSE Director, Mark Keily 07815 650763 markkeily@sunbeltrentals.co.uk (who has been appointed by the Board to act as the Company’s Designated Whistleblowing Officer (DWO).

Alternatively, a disclosure may be made to the Sunbelt Rentals Chief Executive Officer and/or to the Ashtead Group PLC Group Legal Counsel.

Employees using this procedure should state that they are making a report or disclosure using the Whistleblowing Policy and specify whether they wish their identity to be kept confidential.

 Employees making a disclosure under this policy are entitled to be accompanied by a workplace colleague or union representative at any meeting that takes place in connection with the disclosure. Any companion will be asked to respect the confidentiality of the disclosure and any subsequent investigation.

We recognise that disclosures made under this policy may involve highly confidential and sensitive matters and that employees may prefer to make an anonymous disclosure. Although anonymous disclosures can be made using the Sunbelt Rentals AlertLine facility (Telephone 0844 892 4413). However, 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.

All Whistleblowing reports will be investigated and the employee will be informed of the outcome of the investigation and what action, if any, has been taken.

If the employee remains unhappy about the speed or conduct of the investigation, or the way in which the matter has been resolved, he/ she should refer the matter to the Ashtead Group PLC Group Legal Counsel who will arrange for a senior manager to review the actions taken in connection with the initial disclosure.

Following further investigation of the complaint, the employee will be informed of the result and what, if any, action has been taken.

We envisage that disclosures will be most likely to relate to the actions of our employees, officers or directors but they may also relate to the actions of a third party, such as a client. In such cases it may be appropriate for you to raise your concerns directly with the third party where you believe that the malpractice identified relates solely or mainly to their conduct or a matter which is their legal responsibility.

However, we would ask that you consult the DWO before speaking to the third party.

The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any workplace wrongdoing. It is therefore hoped that it will not be necessary for employees to alert external organisations. However, in very serious circumstances, or following an internal report which has not been addressed, we recognise that it may be appropriate for you to report your concerns to an external body, such as a regulator.

The government has prescribed a list of appropriate bodies for such external reporting: for example, the Environment Agency and the Health and Safety Executive. A full list is available from an independent charity called Public Concern at Work, who can be contacted by telephone on 0207 404 6609. Equally the Company recognises that there may be matters that it cannot properly deal with internally and in respect of which external authorities will need to be notified and become involved either during or after our investigation. We will

endeavour to inform you if we propose to make a referral to an external authority, although we may need to make such a referral without your knowledge or consent if we consider it appropriate.

Confidentiality

Every effort will be made to keep the identity of an individual who makes a disclosure under this policy confidential, at least until any formal investigation is under way. In order not to jeopardize the investigation into the alleged malpractice, the employee making a disclosure will also be expected to keep the fact that they have raised a concern, the nature of the concern and the identity of those involved confidential.