Purpose

Q-Park encourages a free and open culture in dealings between its managers, employees and all people with whom it engages in business and legal relations. In particular, this Company recognises that effective and honest communication is essential if concerns about breaches or failures are to be effectively dealt with.

Scope

This policy is applicable to all employees of Q-Park as well as contractors who undertake activities on behalf of the Company and any visitors, clients and/or customers on the Company's premises.

Policy statement

This policy is designed to provide guidance to all those who work with or within the Company who may from time to time feel that they need to raise certain issues relating to the Company with someone in confidence.

Aims of the policy

The aim of this policy is to encourage employees and others who have serious concerns about any aspect of Q-Park’s work to come forward and voice those concerns.

The policy is designed to ensure that individuals can raise concerns about wrongdoing or malpractice within the Company without fear of victimisation, subsequent discrimination, disadvantage or dismissal.

It is also intended to encourage and enable employees to raise serious concerns within the Company rather than ignoring a problem or 'blowing the whistle' outside of the Company.

This policy aims to:

• Encourage employees to feel confident in raising serious concerns at the earliest opportunity and to question and act upon concerns about practice.
• Provide avenues for employees to raise those concerns and receive feedback on any action taken.
• Ensure that employees receive a response to their concerns and that they are aware of how to pursue them if they are not satisfied.
• Reassure employees that they will be protected from possible victimisation if they have made a disclosure in good faith.

Principles

This policy will apply in cases where employees genuinely believe that one of the following sets of circumstances is occurring, has occurred or may occur within the Company and that it is in the public interest for the employee to disclose it. The matters that may be disclosed in this way are that:

• A criminal offence has been committed, is being committed or is likely to be committed.
• A person has failed, is failing or is likely to fail to comply with any legal obligation to which they are subjected to.
• A miscarriage of justice has occurred, is occurring or is likely to occur.
• The health and safety of any individual has been, is being or is likely to be endangered.
• The environment has been, is being or is likely to be damaged.
• Information tending to show any matter falling within any one of the preceding paragraphs has been, is being or is likely to be deliberately concealed.

There is no need for employees to prove that the breach or failure that they are alleging has occurred or is likely to occur as a reasonable belief or suspicion will suffice, i.e. where the employee reasonably believes that the information disclosed is substantially true. Employees should, however, note that they are not entitled to make a disclosure if in so doing they commit a criminal offence.

If employees wish to raise or discuss any issues which might fall into one of the categories listed above, they should contact their manager or HR. This manager or HR will, insofar as is possible, treat the matter in confidence. It is likely that an investigation will be necessary and the employee who has made the disclosure may be required to attend an investigatory meeting and potentially provide a witness statement. Appropriate steps will be taken to ensure that the employee’s working relationships are not prejudiced by I Ithe fact of the disclosure.

Employees may make such a disclosure to Public Concern at Work (the leading authority on public interest whistleblowing), if they consider that it has an interest in the matter and, despite the best efforts of the Company, employees believe that disclosure within the Company is inappropriate or has been unsuccessful. Disclosures made to employees' legal advisors in the course of obtaining legal advice will be protected.

Employees should be aware that this policy will apply where they reasonably believe that the information disclosed and any allegation contained in it are substantially true. If any disclosure concerns information which employees do not substantially believe is true, or indeed if the disclosure is made for personal gain, then such a disclosure will constitute a disciplinary offence for the purposes of the Company’s disciplinary policy and procedures and may constitute gross misconduct for which summary dismissal is the sanction.

While the Company hopes that such disclosures will never be necessary, it also recognises that it may find itself in circumstances which are new to it. Each case will be treated on its own facts.

Employees who make a disclosure are protected from detrimental treatment by the Company, by a co-employee or by an agent of the Company. If this occurs, it should be raised immediately with the employee’s manager so that the matter can be investigated thoroughly without undue delay. Detrimental treatment includes, for example, harassment and bullying or not complying with a person’s rights and entitlements under their contract of employment.