Whistleblow Policy

Purpose and Scope

We are committed to creating and maintaining a culture of openness within our organization so that individuals feel encouraged and confident to raise any concerns relating to suspected misconduct at an early stage.  

We also recognise the negative effect which malpractice can have on the organization, and therefore encourage you to raise genuine concerns, or any suspicions you may have concerning misconduct.

Disclosures Under this Policy

You can make a disclosure under this Policy if you have genuine concerns relating to any of the following areas of malpractice, or suspected malpractice:

  • Criminal activity;
  • Miscarriages of justice;
  • Practices endangering health and safety;
  • Practices damaging the environment;
  • Failure to comply with a legal obligation;
  • Failure to comply with companies Supply Chain Policy for a Responsible Global Supply Chain of Minerals from Conflict-Affected and High-Risk Areas;
  • Bribery;
  • Financial malpractice, impropriety or fraud;
  • Serious failure to comply with any ethical rules covering the business;
  • Attempts to conceal any of the above.

The malpractice can be past, present or prospective. 

You are encouraged to report suspected wrongdoing as soon as possible. No action will be taken against you if you raise genuine concerns even if the concern you raised is not confirmed by any subsequent investigation.


Once a concern has been raised, we will investigate it.  If you have not made the complaint anonymously, you will be asked to attend a meeting as part of this investigation.  

We will keep you informed as to the progress of the investigation, as far as is possible and appropriate bearing in mind, in particular, any confidentiality obligations that apply.

Please note that you will not be given details of any disciplinary action taken unless we consider this appropriate.


All of our workers will receive an appropriate briefing to ensure that they are fully aware of their rights and responsibilities under this Policy.  

All managers will be fully briefed as to their role in supporting this Policy and the appropriate action to take in the event of any disclosure being made to them.


If you want to become our partner or have any additional questions please feel free to contact us.