Whistleblowing

The whistleblowing policy is underpinned by the principle that the highest standards of honesty and integrity are fundamental in all areas of Brickability Group PLC. This means being transparent in what we do and say and accepting responsibility for our actions. Any fraud, misconduct, or wrongdoing by the Company or its employees should be reported.

We believe that it is essential to create an environment in which employees and suppliers feel able to raise concerns internally without fear of disciplinary action or retaliation. For suppliers, please see the "Supplier Reporting" section below.
This policy outlines the process for raising concerns, ensuring that they are properly investigated and resolved in a timely manner.

This procedure applies to:
• All employees of Brickability Group PLC and its subsidiaries.
• Contracted workers engaged in our business.
• Suppliers and their workers, who can report concerns under the Supplier Reporting section.

Brickability Group PLC is committed to:
• Ensuring this policy is applied consistently across the business.
• Encouraging individuals to raise concerns as soon as possible.
• Providing a secure and confidential reporting process.
• Protecting whistleblowers from retaliation or victimisation.
• Ensuring that concerns are fully investigated and appropriate action is taken.
• Training line managers to handle whistleblowing disclosures effectively.
• Updating this policy in line with legislation and best practices.

Managers are responsible for:
• Creating a culture where employees feel safe to raise concerns.
• Listening and responding to concerns promptly.
• Referring cases to the appropriate internal team for investigation.

Employees and contractors are expected to:
• Raise concerns as soon as possible.
• Follow internal reporting processes before escalating externally.
• Refuse to accept or ignore any unacceptable practices.

The Public Interest Disclosure Act 1998 protects employees from dismissal or disciplinary action when they report wrongdoing by their employer. Examples of qualifying disclosures include:
• A criminal act.
• Failure to comply with a legal obligation.
• A miscarriage of justice.
• Health & safety breaches.
• Damage to the environment.
• Concealment of any of the above.
• Any suspected fraudulent activity.
Brickability Group PLC strongly believes that individuals who report wrongdoing should not be victimised for speaking up.

• Everyone should be aware of the importance of preventing and eliminating wrongdoing.
• Any concerns raised under this policy will be investigated thoroughly, promptly, and confidentially.
• No employee will suffer victimisation, dismissal, or discrimination for making a legitimate disclosure.
• If misconduct is found, appropriate disciplinary and legal action will be taken.
• False or malicious allegations are considered a disciplinary offence.

Where possible, concerns should be raised internally through:
1. Line Manager – If appropriate, concerns should first be discussed with your manager.
2. Senior Manager or Director – If the concern involves your line manager, it should be referred to a Senior Manager or Director.
3. Grievance Procedure – If you choose to raise a concern through the grievance process, please state that you are following this route.
4. External Contact – If previous steps are inappropriate contact Safecall an independent confidential reporting line where you can raise your concerns. Calls are handled by skilled staff and will be treated in complete confidence. Safecall will not disclose your name if you wish to remain anonymous. Lines are open 24/7 on
www.safecall.co.uk/freephone
www.safecall.co.uk/report

If the above procedures are exhausted and you reasonably believe the appropriate action has not been taken, you may report concerns to external regulatory bodies such as:
• HM Revenue & Customs
• Financial Conduct Authority
• Office of Fair Trading
• Health & Safety Executive
• Environment Agency
Brickability Group PLC recognises that in some cases, no wrongdoing may be found. However, if a disclosure is made in good faith, no disciplinary action will be taken against the whistleblower.

The investigating officer will follow these steps:
1. Obtain full details of the complaint and clarify any uncertainties.
2. Inform the accused individual (if applicable) and allow them to respond.
3. Determine if external bodies (e.g., police, auditors) should be informed and refer if necessary
4. Conduct a full and fair investigation, involving external experts if necessary.
5. Issue a written report summarising findings and recommended actions.
6. Decide on disciplinary action if misconduct is confirmed.
7. Inform the whistleblower of the outcome (where possible).
If a whistleblower is not satisfied with how their concern has been handled, they may escalate the issue to the CEO.

Brickability Group PLC has extended its whistleblowing process to enable suppliers and workers within our supply chain to report concerns, including potential modern slavery, unethical labour practices, or other serious wrongdoing.
Suppliers can report concerns confidentially via:
• www.safecall.co.uk/freephone
• www.safecall.co.uk/report

• Reports will be fully investigated, and appropriate action will be taken.
• Suppliers and their workers will be protected against retaliation.
• Concerns may be raised anonymously where required.
 

Frank Hanna
CEO
June 2025