Right to Speak Policy

Commitment and responsibility

Essentra is committed to ensuring that all of its international activities are conducted in accordance with all applicable legal and regulatory requirements and the highest standards of ethical business conduct.

It is the responsibility of all Essentra employees to ensure that none of Essentra’s businesses engage in practices which infringe legal or regulatory requirements or which fall below the highest standards of ethical business conduct.

Any Essentra employee engaging in business practices which infringe legal or regulatory requirements or fall below the highest standards of ethical business conduct may be subject to disciplinary action which may lead to dismissal and may face personal criminal or civil liability.

It is the responsibility of all Essentra employees to ensure that they report any infringement or suspected infringement of legal or regulatory requirements or the highest standards of ethical business conduct involving Essentra to their line manager or otherwise in accordance with the Essentra Right to Speak Policy.

The Right to Speak policy (‘Policy’)

Essentra plc, together with its affiliates and subsidiaries (together or individually ‘Essentra’ or ‘the Company’), is committed to upholding the highest standards of honesty and integrity. In accordance with the Essentra Ethics Code, the Board expects all employees across Essentra to maintain the highest standards of business conduct and personal behaviour at all times in performing their duties responsibly, honestly and lawfully.

For the purposes of this policy, the term “employee” means employees (whether fixed term, permanent or temporary) directors, officers and other individuals working for the Company such as contractors and agency workers.

In support of Essentra’s commitment and the Board’s expectations, the Company seeks to maintain a culture of openness and accountability, such that prompt action can be taken to address any illegal or unethical conduct involving Essentra or any of its employees. Essentra will not tolerate attitudes or activities that constitute a breach of law or trust, or otherwise fall below the highest standards of business conduct and personal behaviour.

This Right to Speak policy formalises Essentra’s procedure to enable any employee to make fair and prompt disclosure of any circumstances where the employee genuinely and reasonably believes that the Company and/or any employee is engaged in any activities or practices which fail to meet the highest standards of business conduct expected by the Essentra Ethics Code and personal behaviour.

The aims of this Policy are:

i. To make employees aware that

  • genuine and reasonable suspicions of illegal or unethical activities or inappropriate practices should be reported as soon as possible
  • any concerns will be taken seriously
  • any allegations will be thoroughly investigated and action taken as appropriate
  • confidentiality will be respected

ii. To provide employees with guidance as to how to raise any concerns

iii. To support employees and reassure them that

  • they are able to raise genuine and reasonably held concerns in good faith without fear of reprisals, even if they turn out to be mistaken
  • they will be protected against reprisal and retaliation

The Policy does not form part of any employee's contract of employment and it may be amended at any time.

What types of activities or practices should an employee disclose under the Essentra Right to Speak policy?

Any information which relates to suspected activities or practices which fall below the highest standards of business conduct, personal behaviour and the Essentra Ethics Code should be disclosed under the Policy. This may include

  • criminal activity;
  • dangers to health and safety;
  • damage to the environment;
  • failure to comply with any legal or regulatory requirements;
  • financial fraud or mismanagement;
  • the deliberate concealment of any of the above matters
  • unethical behaviour

The above list is not exhaustive and employees should not be discouraged from making any disclosure of concerns that they may have simply because those concerns do not fall within the categories identified.

When should an employee raise any concerns under the Essentra Right to Speak policy?

Employees are encouraged to use their judgement prior to raising any concerns under the Right to Speak policy.

Employees do not need absolute proof of their suspicions, but those suspicions should be genuine and based on a reasonable belief of the relevant circumstances.

Any disclosures should be made in good faith.

Essentra’s commitment is to maintaining honesty and integrity. Employees must be aware therefore that if they make a false report in bad faith they may face disciplinary action.

Employees should not use the Right to Speak policy for any issues or complaints relating to their own personal circumstances at work. Employees should follow the Company’s Human Resource grievance or other procedures established at their place of work for handling such matters.

How do employees make a disclosure under the Essentra Right to Speak policy?

At first instance, employees are encouraged to raise any concerns requiring disclosure with their line manager, human resource representative or other management within their immediate working environment. Procedures are established across the Group for the prompt escalation of any issues requiring review by more senior management.

If employees feel that they need to raise the issue outside of their immediate working environment at any time, the Company has put in place, through an independent third party, the ‘Essentra Ethics Point Helpline’ on T: 0808-234-3322. This is a confidential call centre manned 24 hours a day by appropriately trained individuals.

Alternatively employees can register with Essentra Ethics Point through their website essentra.ethicspoint.com and file a confidential complaint.

All complaints received through the Essentra Ethics Point Helpline will be notified to the Senior Review Team established at Essentra plc. The Review Team consists of the Group Finance Director, Company Secretary & General Counsel and director of Group Human Resources.

If the complaint is of an employee related matter it will also be referred to the Regional Human Resources director or senior vice president. The regional representatives will be responsible for investigating such complaints. In order to proceed with an accurate and thorough investigation it will be necessary for local human resource persons to be notified and assigned the complaint.

The Company will aim to acknowledge receipt of any complaints received within two working days and then aim for an initial investigation report to be made available to the Reporter within five working days.

How will the company respond to any disclosures made by an employee?

Essentra will arrange for the proper and appropriate investigation of any disclosures made by any employee under the Policy. Investigations will be conducted promptly and fairly with due regard to the nature of any allegations and the rights of the individuals subject to the allegations.

Depending on the nature of the allegations, employees’ concerns will either be dealt with by internal management or they may be referred to an appropriate external body, such as the police, regulatory bodies or professional firms.

The person appointed to investigate the complaint will not have any direct interest in the subject matter or employee of the disclosure.

Subject to any recommendations from the police, regulatory bodies or the Company’s professional advisers, and the rights of the individuals subject to the allegations, the Company will advise the employee responsible for making the disclosure of the findings of the investigation and any actions to be taken as a result.

If any investigation concludes that an employee has made false allegations in bad faith that employee may be subject to disciplinary action.

In the operation of the Policy the Company will have due and proper regard to applicable Data Protection legislation in order to ensure that the rights of individuals are respected as appropriate.

Confidentiality and protection from reprisals

Essentra is committed to ensuring that employees feel able to raise concerns openly in good faith under the Right to Speak policy without fear of reprisal or retaliation and with the support of the Company.

Where an employee genuinely believes that there is some form of wrongdoing or danger at work and a concern is raised in accordance with the Policy, the Company will take all reasonable steps to ensure the employee does not suffer any disadvantage in the workplace as a result of speaking up about concerns.

If a concern turns out not to be well founded, provided that the concern was genuine at the time the concern was raised and the employee did not commit any misconduct collating evidence regarding their concern, the Company will take all reasonable steps to ensure there is no disadvantage in the workplace suffered as a result of speaking up nor will an employee lose their legal protection as a result.

The Company will seek to carry out its investigations in a confidential and sensitive manner and the number of persons involved and who are privy to the details of the concerns, including the identity of the employee raising the concerns will be kept to a minimum.

Essentra does not encourage employees to make anonymous disclosures as the proper investigation of any allegations may be prejudiced and the credibility of those allegations called into question. However, if employees do wish to preserve anonymity and/or confidentiality, then the Company will make every effort to respect that whilst conducting whatever investigation may be appropriate or possible in the circumstances.

Employees should be aware that should any disclosures result in a criminal or other regulatory investigation, they may be asked to be a witness.

It would not normally be appropriate for an employee to discuss concerns about the Company outside the Company or to a third party unless the procedures detailed in this Policy have first been followed. An employee who disregards this Policy and makes a disclosure to a third party where it is not appropriate to do so may be in breach of confidentiality duties owed to the Company (which may lead to disciplinary action being taken) and may lose their statutory protection for raising whistleblowing concerns.

What if an employee is not satisfied with the outcome of any investigation under the Essentra Right to Speak policy

Essentra’ is committed to ensuring that any disclosures are thoroughly investigated and appropriate actions taken to address any issues arising from that investigation. If any employee is dissatisfied with the manner in which their concern has been handled then, they should write to the Audit Committee Chairman, Essentra plc, 201-249 Avebury Boulevard, Milton Keynes, United Kingdom, MK9 1AU.