Whistleblowing Policy

We’re committed to doing the right thing for our people, our customers, our partners, our community, and the environment. Integrity, transparency, and accountability sit at the heart of how we work.

This policy provides a safe and confidential way for anyone connected with the company to raise concerns about wrongdoing, unlawful behaviour, or anything that doesn’t feel right.

This policy applies to:

• All employees (full-time, part-time, and temporary)

• Contractors, agency workers, consultants, suppliers, and other third parties associated with the company

What can be reported

You should speak up if you see or suspect something that feels unlawful, unsafe, dishonest, or against our values. Examples include (but are not limited to):

• Fraud, bribery, corruption, or theft

• Financial malpractice or misreporting

• Health and safety risks

• Harassment, bullying, or discrimination

• Breaches of legal or regulatory obligations

• Breaches of internal company policies

• Abuse of authority or misuse of company resources

• Environmental damage

• Negligence

• Any other unethical or improper conduct

Grievance or whistleblowing?

This policy is intended for issues involving serious misconduct, wrongdoing, or matters in the public interest that could affect others across the business.

Concerns relating to personal employment matters (e.g., pay, workload, or disputes with colleagues) should normally be addressed under the Grievance Policy through your line manager or the HR team.

If you are unsure which process is appropriate, you may speak to HR in confidence or use our independent reporting service (see section 6: Reporting a concern).

Protection when you speak up

Under the Public Interest Disclosure Act 1998 (PIDA), individuals who disclose concerns in the public interest, such as suspected wrongdoing, criminal offences, risks to health and safety, environmental harm, or other serious breaches are protected from retaliation.

To qualify for protection under PIDA, the disclosure must be made in good faith and in the public interest, not solely for personal reasons.

Reporting a concern

Independent reporting – Speak Up

To ensure impartiality and confidentiality, we have partnered with Health Assured, an independent third-party to manage our Whistleblowing service via Speak Up.

How to report

You can raise concerns via Health Assured:

• Telephone: 0800 047 4037 (available 24/7, 365 days) When connected to the main reception, say you’d like to be referred to the Whistleblowing / Speak Up service.

• Website: www.healthassured.org

All reports are securely forwarded to whistleblowing@baxterfreight.com, a restricted inbox monitored by HR and the Board of Directors.

What happens next

Once a disclosure is received:

• Health Assured prepares a secure, password-protected report.

• HR and the Board of Directors conduct a preliminary assessment.

• After initial review, the Company will decide what, if any, action is appropriate. This may include informal resolution, formal investigation, or no further action if there is insufficient information or evidence. Any action taken in line with Baxter Freight’s Code of Ethics and Disciplinary Policy.

• If contact details are provided, updates may be shared with the whistleblower where appropriate.

All disclosures made via Speak Up are treated as formal whistleblowing reports under this policy and will be managed in line with legal obligations.

Confidentiality

All disclosures will be handled in strict confidence. Your identity will not be disclosed without your consent, except where required by law, necessary for a fair investigation, or where the company reasonably determines that escalation is appropriate (for example, to the Board, relevant colleagues, regulators, or external authorities such as the Police). Once a disclosure has been made, the company will decide the most appropriate course of action.

Anonymous disclosures are accepted. While anonymity may limit our ability to investigate fully or provide feedback, all such reports will be taken seriously and considered carefully. You may choose to identify yourself at any stage of the process, in which case confidentiality protections under this policy will apply.

Protection from retaliation

We will never tolerate retaliation against anyone who raises a concern in good faith. Retaliation includes, but is not limited to:

• Dismissal, demotion, or exclusion

• Harassment or victimisation

• Adverse changes to working conditions

This protection applies to:

• Individuals protected under PIDA

• Individuals protected under the Equality Act 2010 who report discrimination or harassment

Any act of retaliation will be treated as a serious disciplinary matter.

False or malicious allegations

Knowingly making false reports or submitting information in bad faith is a serious disciplinary offence. This does not apply to concerns raised in good faith that later prove to be unfounded.

Support services

We understand raising concerns can be difficult. Everyone using the Speak Up service has access to immediate, confidential counselling and emotional support through Health Assured.

Training and awareness

All employees will receive training on whistleblowing procedures. Regular reminders and updates will be provided to ensure awareness.

Policy review

This policy will be reviewed annually, or in response to changes in legislation or company practices. This policy is introduced during onboarding and supported through ongoing training. Speak Up service contact details are stored on the HR System under company documents.