Complaints and Speak-Up (Whistleblowing) Policy

1Purpose

1.1Eurabelt Fuels Ltd wants to know when something has gone wrong or may go wrong. This policy explains how anyone can make a complaint about the CSR programme or raise a concern about wrongdoing, and how Eurabelt protects those who do.

2Who may use this policy

2.1This policy is open to everyone: directors, employees and representatives of Eurabelt, applicants and partner organisations and their staff, beneficiaries, and members of the public.

3Complaints

3.1A complaint about the way Eurabelt has handled an application, a partnership or an enquiry may be sent to csr@eurabeltfuels.com. Please give your name, your organisation if any, a description of the matter and the outcome you seek.

3.2We acknowledge complaints within five working days and aim to give a full response within 20 working days. If that is not possible, we will tell you why and when to expect a response. If you are not satisfied with the response, you may ask for the complaint to be reviewed by Compliance at compliance@eurabeltfuels.com.

3.3A decision to decline an application is at the discretion of Eurabelt, as set out in EBF-CSR-POL-04, and is not in itself a ground for complaint; the way in which an application was handled may be.

4Concerns about wrongdoing

4.1Please speak up if you have reasonable grounds to believe that any of the following has occurred, is occurring or is likely to occur in connection with the programme:

• bribery, corruption, fraud, theft or misuse of funds;
• a breach of sanctions or of any other law;
• a risk to the safety of a child or an adult at risk;
• a danger to health, safety or the environment;
• an undeclared conflict of interest;
• the deliberate concealment of any of these matters.

4.2Reports should be made to compliance@eurabeltfuels.eu. You may report in confidence, and you may report anonymously, although anonymous reports can be harder to investigate. Please give as much detail as you can, but do not investigate the matter yourself.

5Impersonation of Eurabelt

5.1Eurabelt corresponds only from company addresses on its own domains, and only the people listed on the Leadership page of eurabeltfuels.uk act for the company. Anyone else has no authority to use its name.

5.2If you are contacted by anyone claiming to act for Eurabelt who is not so listed, or by anyone who asks for a fee or payment in connection with the CSR programme, please report it to compliance@eurabeltfuels.eu, attaching the message and any details of the sender. Do not make any payment.

6Protection from retaliation

6.1No one who raises a concern in good faith will suffer any detriment, dismissal, disciplinary action, threat or other unfavourable treatment as a result, even if the concern turns out to be mistaken. Retaliation against anyone who speaks up is itself a serious breach of this policy.

6.2Workers are protected by the Public Interest Disclosure Act 1998 when they make a qualifying disclosure in the public interest. Nothing in this policy prevents anyone from reporting a matter directly to a regulator, a prescribed person or the police, or from seeking independent legal advice.

6.3Knowingly making a false report is a breach of this policy.

7How concerns are handled

7.1Compliance acknowledges every report within five working days, assesses it, and arranges for it to be investigated by a person independent of the matter. The identity of the person reporting is kept confidential and shared only with those who need it, unless the law requires otherwise. Where appropriate, the person reporting is told the outcome, subject to legal and confidentiality limits.

7.2Records of complaints and concerns are kept securely, in accordance with the Privacy Notice (EBF-CSR-POL-02).

8Review

8.1This policy is owned by Compliance and reviewed at least once a year.