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WHISTLEBLOWING & RAISING CONCERNS POLICY

Ref: HPOL23 | Version: 1.0 | Date: 17/02/2026 | Classification: CRGI Information

Version Date Author Changes
1.0 17/02/2026 Sean Ashton Initial issue — new policy for 2026, reflects Employment Rights Act 2025 and Fair Work Agency provisions

Policy Statement

CRGI Solutions encourages all staff to raise concerns about wrongdoing, malpractice, or dangers in the workplace without fear of reprisal. We are committed to maintaining a culture of openness and accountability where staff feel safe to speak up. This policy provides a framework for raising concerns internally and, where necessary, externally through prescribed channels.

Key Requirements

  1. Staff shall raise genuine concerns about suspected wrongdoing, including health and safety dangers, environmental damage, fraud, bribery, criminal activity, breaches of legal obligations, or deliberate concealment of any of these matters.
  2. Concerns may be raised with the Operations Manager in the first instance. Where the concern relates to the Operations Manager, it shall be raised directly with the CEO.
  3. All concerns raised shall be taken seriously, treated confidentially so far as is reasonably possible, and investigated promptly by the appropriate person.
  4. Staff who raise genuine concerns in good faith shall not be subjected to any detriment, disciplinary action, or victimisation, regardless of the outcome of the investigation.
  5. Anonymous concerns shall be accepted and investigated where possible, although named disclosures are preferred to enable thorough investigation and feedback.
  6. If internal channels do not resolve the concern, or if the concern relates to both management tiers, staff may raise the matter externally with a prescribed person or body (e.g. HSE, Environment Agency, or the Fair Work Agency).
  7. Malicious or vexatious allegations made in bad faith may be treated as a disciplinary matter.
  8. Records of concerns raised, investigations conducted, and outcomes shall be maintained confidentially by the investigating manager.
  9. This policy shall be communicated to all staff during induction and made available through the HSQEMS site.

Applicable Legislation

  • Employment Rights Act 1996 — Part IVA (Protected Disclosures)
  • Employment Rights Act 2025 — Fair Work Agency, strengthened whistleblower protections (from April 2026)
  • Public Interest Disclosure Act 1998
  • Enterprise and Regulatory Reform Act 2013
Reference Document
HPOL07 Code of Conduct
HPOL08 Equal Opportunities Policy
HPOL09 Anti-Bribery & Corruption Policy
HSQEMS03 Roles & Responsibilities
HSQEMS01 IMS Manual — Section 11 (Non-Compliance & Disciplinary Framework)
Role Name Signature Date
Owner Sean Ashton, Operations, HSQE & Technical Manager S.Ashton 17/02/2026
Approved Dragos Ciordas, Chief Executive Officer D.Ciordas 17/02/2026

Approved by: Dragos Ciordas, CEO — 17 February 2026 Next Review: February 2027 Distribution: All Staff