This policy is designed to encourage employees and other stakeholders to report suspected wrongdoing as soon as possible, in the knowledge that their concerns will be taken seriously and investigated appropriately, and that their confidentiality will be respected.

This policy applies to all employees, contractors, suppliers, and other third parties connected to the organisation, and any other individuals or entities acting on behalf of, or in association with, the organisation in any jurisdiction where it operates.

Whistleblowing is the disclosure of information which relates to suspected wrongdoing or dangers at work. This may include:

• Criminal offenses (e.g., fraud, corruption, theft)
• Failure to comply with legal obligations
• Miscarriages of justice
• Health and safety dangers
• Environmental damage
• Bribery
• Any attempt to conceal any of the above

Concerns should be raised with:

• Line Manager or Supervisor
• HR Department
• Your relevant contact at APG

If you prefer to report anonymously, you can do so by using the whistleblower email
(Whistleblowing@apgecommerce.com), or using our APG Whistleblower form

All disclosures will be handled with strict confidentiality to the extent legally permissible. The identity of the whistleblower will not be disclosed without their explicit consent, except as required by law or necessary for a proper investigation.

Whistleblowers will not suffer any detrimental treatment as a result of raising a concern in good faith. Retaliation against whistleblowers is prohibited and may lead to disciplinary action.

Once a concern is raised:

• It will be acknowledged within 1-3 days.
• An initial assessment will be conducted.
• If necessary, a formal investigation will follow.
• The whistleblower may be kept informed as appropriate.

Deliberately false or malicious allegations may result in disciplinary action. However, no action will be taken against individuals who report in good faith, even if the concern is later found to be unsubstantiated.

The organisation will provide training and communication to ensure all employees are aware of this policy and how to use it.

This policy will be reviewed annually and updated as necessary to reflect best practices and legal requirements.