(Making a Disclosure in the Public Interest)
Last updated: 16.9.25

Introduction

Allfresch Group Ltd is committed to the highest standards of openness, integrity and accountability. We recognise the importance of providing a clear process for staff, suppliers and partners to raise concerns about serious malpractice or wrongdoing without fear of reprisal.

This policy supports the Public Interest Disclosure Act, which protects employees who disclose certain types of information in the public interest. It is not intended to cover personal grievances, which should be addressed through the company’s other procedures.

Scope

This policy allows individuals to raise concerns which may include, but are not limited to:

• Financial malpractice, impropriety or fraud

• Breach of legal or regulatory obligations

• Risks to health, safety or the environment

• Criminal activity

• Improper conduct or unethical behaviour

• Attempts to conceal wrongdoing

• Product safety, legality and authenticity

Safeguards

Protection – Employees who raise genuine concerns in good faith will be protected from dismissal, victimisation or other disadvantage.
Confidentiality – Disclosures will be handled sensitively. While anonymity cannot always be guaranteed, identities will only be shared where necessary.
Anonymous disclosures – Anonymous concerns may be considered at the company’s discretion, taking into account seriousness, credibility and the possibility of corroboration.
Untrue or malicious allegations – No action will be taken if an allegation made in good faith is not substantiated. However, malicious or vexatious claims may result in disciplinary action.

Reporting Concerns

Concerns should be raised as soon as possible with an appropriate investigating officer:

• Normally, complaints will be investigated by a Director.

• If the complaint involves a Director, it should be reported to the Group Managing Director (GMD).

• If the complaint involves the GMD, it should be reported to another Director, who will appoint an appropriate investigating officer.

Employees have the right to bypass line management and raise concerns directly with the GMD. Where none of the above routes are appropriate, employees may raise concerns directly with a designated independent contact.

Where criminal activity is suspected, the police will be informed. Internal investigations will not obstruct formal investigations.

Investigations

The investigating officer will:

1. Obtain full details of the complaint.

2. Inform the subject of the complaint, who has the right to representation.

3. Consider the involvement of auditors or police, if appropriate.

4. Conduct a full investigation, supported as necessary by external parties.

5. Produce a written report with findings and recommendations.

6. Submit the report to the Directors for action.

The complainant will be kept informed of progress and notified of the outcome in writing, subject to legal and confidentiality constraints.

Timescales

While it is not possible to guarantee exact timescales, all concerns will be addressed as quickly as possible without compromising the quality of the investigation. A written acknowledgement will be sent promptly upon receipt, with progress updates provided during any extended investigation.

Escalation

If a complainant is not satisfied with how their concern has been handled internally, they may raise it in confidence with a Director, or with a prescribed external body such as the Health and Safety Executive. A full list of prescribed persons and bodies is available on the UK Government website (www.gov.uk).

Suppliers and Extended Communities

Suppliers, partners and communities affected by our operations are also encouraged to report unethical practices or concerns about our activities. These will be investigated using the same process as outlined above.

Concerns may be reported via:
Phone: +44 (0) 1952 460608