Whistleblower Policy

Policies and reports

Concerning potential breaches of Code of Conduct

I. Introduction

As set out in the Group's Code of Business Conduct, RB is committed to high standards of corporate behaviour towards employees, customers, suppliers, consumers, governments and communities in which we operate. As part of this commitment this policy provides a mechanism to enable employees to voice Code of Conduct concerns in a responsible and effective manner. RB will treat all such disclosures in an appropriate and sensitive manner.

It should be emphasised that this policy is designed to assist individuals who believe that they have discovered malpractice or impropriety. It is not designed to question financial or business decisions or to cover employee grievances, which should be dealt with in accordance with the group guideline on "Avoidance of grievance", a copy of which is available from local HR departments.

II. Scope of policy

The policy is designed to enable all RB employees to raise concerns internally and at a senior level and to disclose information which the individual believes shows malpractice or impropriety within the group. These concerns could include:

  • Financial malpractice or impropriety or fraud
  • Failure to comply with legal obligations
  • Dangers to health and safety or the environment
  • Criminal activity
  • Improper conduct or unethical behaviour
  • Significant breaches of the Code of Conduct and associated policies
  • Attempts to conceal any of the above once they have occurred

However, this is not intended to be an exhaustive list.

III. Confidentiality

This policy is designed to give employees confidence that genuine concerns they have will be treated seriously, that they will suffer no intimidation as a result of raising genuine concerns and to provide an indication of the seriousness with which the Company manages such issues.

The Company recognises that employees in these circumstances may not always feel comfortable raising the issue either with their direct line manager or anyone else within the Company. Therefore, in order to support employees who nonetheless wish to voice concerns, the Company has set up an arrangement with a confidential third party hotline where issues can be disclosed and concerns aired. The Company encourages individuals to put their name to any disclosures they make.

Concerns expressed anonymously are much less powerful, but they will be considered at the discretion of the Company. However, the third party hotline provider will not disclose the identity of the caller unless the caller has consented for this to be done. The only exception to this confidential approach relates to instances where the Company or the hotline provider is under a legal obligation to disclose information to public authorities, for instance in the case of certain very serious types of criminal conduct.

If the individual does decide to disclose his or her identity to senior Group management, either directly or via the hotline provider, and makes an allegation in good faith which is not confirmed by subsequent events no action will be taken against this individual and their identity will remain confidential. In making a disclosure, however, the individual should exercise due care to ensure the accuracy of the information disclosed.

IV. Employee rights

The Company will take the necessary steps to ensure that an employee has the right to report in a responsible manner any malpractice or impropriety without being penalised by his/her peers or superiors. The Company will also ensure that an individual will not suffer any reprisals or victimisation as a result of voicing concerns on such matters in good faith.

V. Untrue allegations

If an individual knowingly makes malicious or untrue allegations and particularly if he or she persists in repeatedly making them on an ongoing basis, this will be treated as a breach of our Code of Conduct.

VI. Procedures for making a disclosure

  1. The Company would always encourage employees to raise concerns internally in the first instance with their direct line manager or, in the event that this is inappropriate, another senior person in the business.

  2. If having disclosed the concern internally, the individual raising the concern is not satisfied by the response (or lack of response), and it is believed to be inappropriate to refer the matter to any one of the people referred to above, contact should be made either with Area or Group senior management directly or through the confidential third party hotline.

  3. The confidential hotline provider will initially contact the nominated Internal Audit, Group and relevant Area Compliance and HR senior management contacts to notify them of the allegation; a copy of all reports will also be sent to the Group Head of Internal Audit, the Group Compliance Officer and Group SVP HR. Area management and global functional heads will in turn be notified of any incidents relating to their functions or areas if appropriate.

  4. A decision will then be made in consultation with the relevant Group and Area Compliance Officers as to whether to proceed with a full investigation and how to conduct the investigation. This could be conducted either simply by local HR, by Internal Audit with appropriate support from RB Legal or through the use of specialist external resources.

  5. Group Management have the right to refer the complaint back to Area management if they feel that Area management, without any conflict of interest, can more appropriately investigate the complaint.

  6. If an allegation/concern is found to be well-founded, Group and/or Area senior management will take appropriate action to both correct the issue and (so far as practicable) prevent it happening again.

VII. Timescales

Due to the varied nature of issues which may be raised it is not possible to lay down precise timescales for either internal or external investigations. Investigation will be undertaken as quickly as possible in line with the nature and severity of the allegation/concern without affecting the quality and depth of the investigation.

Initial stage investigations will seek to conclude their enquiries and provide feedback to the Group Head of Internal Audit and the Group and relevant Area Compliance Officers within 2 weeks.

VIII. Investigating procedures

  1. Provided there is sufficient evidence to support the allegation / concern, a full investigation will be conducted with the objective of establishing whether malpractice has occurred. The format of the investigation will vary depending on the circumstances. The investigation may need to be carried out under strict terms of confidentiality i.e. not informing the subject of the complaint until (or if) it becomes necessary to do so, for example as in the case of suspected fraud. Employees making the complaint may be contacted for further information, but only if the employee has given express permission for their name and contact details to be disclosed.

  2. The investigation team will inform the complainant of the results of the investigation and its outcome if this has been requested, provided adequate communication channels exist either directly or indirectly via the confidential hotline.

  3. Group and/or Area senior management as appropriate will decide what action to take in the case of proven breach of Code of Conduct. Such action may include disciplinary or other appropriate procedures.

  4. The Board of RB appreciates the concern shown by individuals in reporting suspected wrong- doing and makes a clear commitment that no employee making a genuine allegation will suffer as a consequence of bringing to their attention or that of senior management a breach or suspected breach of any matters covered by this policy.

 

International freephones

Key instructions

ITFS / ITFS-Combo:
One step dialing- call direct

WWC / DA- Combo:
For all two-step dialing, you will need to first dial your corresponding access code and when prompted, enter the 855 number. You may also see more than one number available to dial to.

Collect Call:
For “Collect Call” dialing, the caller must dial their local operator and ask them to make a reverse charge call/ collect call to 704 number.

 

Country

Type of Line

Freephone number (1st step)

Freephone number

(2nd step if required)

Argentina

ITFS

0800-444-2812

-

Australia

ITFS

1-800-13-9957

-

Austria

ITFS- Combo

0800-296732

-

Austria

DA- Combo

0-800-200-288

8552299304

Bahrain

WWC

Bahrain 800-00-001 Bahrain (military call centers) 800-000-05 Bahrain (military onboard cell phones) 800-000-00

8552299304

Bangladesh

WWC

157-0011

8552299304

Belgium

ITFS- Combo

0800-7-8755

-

Belgium

DA- Combo

0-800-100-10

8552299304

Brazil

ITFS

0800-892-0515

-

Bulgaria

WWC

00-800-0010

8552299304

Canada

US Dialing Plan

8552299304

-

Chile

WWC

Chile (Easter Island) 800-800-311 Chile (Easter Island - Spanish) 800-800-312 Chile (ENTEL) 800-360-311 Chile (ENTEL - Spanish) 800-360-312 Chile (Telefonica) 800-800-288 Chile (Telmex - 800) 800-225-288

8552299304

China

GIS

4009994530

-

Colombia

WWC

Colombia 01-800-911-0010 Colombia (Spanish) 01-800-911-0011

8552299304

Costa Rica

WWC

0-800-011-4114

8552299304

Croatia

WWC

0800-220-111

8552299304

Czech Republic

ITFS

800-144-075

-

Denmark

ITFS- Combo

80-251000

-

Denmark

DA- Combo

800-100-10

8552299304

Egypt

WWC

Egypt (Cairo) 2510-0200 Egypt (cellular throughout Egypt) 02-2510-0200 Egypt (Outside Cairo) 02-2510-0200

8552299304

Finland

ITFS

0800-915946

-

France

ITFS

0800-91-7075

-

Germany

ITFS- Combo

0800-180-0042

-

Germany

DA- Combo

0-800-225-5288

8552299304

Greece

ITFS- Combo

00-800-11002-8935

-

Greece

DA- Combo

00-800-1311

8552299304

Hawaii

US Dialing Plan

8552299304

-

Hong Kong

ITFS

800-908-839

-

Hungary

ITFS

06800-20808

-

India

WWC

000-117

8552299304

Indonesia

WWC

007-801-10

8552299304

Ireland - Eire

ITFS- Combo

1-800-552-072

-

Ireland - Eire

DA- Combo

Ireland 1-800-550-000 Ireland (UIFN) 00-800-222-5528

8552299304

Israel

ITFS

180-931-7148

-

Italy

ITFS

800-797458

-

Japan

ITFS

00531-11-0303 0066-33-830532 0034-800-600152

-

Kenya

Africa Shared Collect

Dial Local Operator and ask them to connect you to 7045261125

7045261125

Korea (South)

ITFS

00308-132884

-

Latvia

ITFS

8000-4923

-

Luxembourg

WWC

800-201-11

8552299304

Malaysia

ITFS

1-800-81-7270

-

Mexico

ITFS

001-855-366-2458

-

Netherlands

ITFS- Combo

0800-023-2214

-

Netherlands

DA- Combo

0800-022-9111

8552299304

New Zealand

WWC

000-911

8552299304

Nigeria

Africa Shared Collect

Dial Local Operator and ask them to connect you to 7045261125

7045261125

Norway

ITFS

800-12183

-

Pakistan

WWC

00-800-01-001

8552299304

Philippines

WWC

Philippines (Bayan) 105-11 Philippines (Digitel) 105-11 Philippines (Digitel - Tagalog) 105-12 Philippines (Globe) 105-11 Philippines (Globe - Tagalog) 105-12 Philippines (Option 2) 105-11 Philippines (Philcom) 105-11 Philippines (Philcom - Tagalog) 105-12 Philippines (PLDT) 1010-5511-00 Philippines (PLDT - Tagalog) 1010-5511-10 Philippines (Smart) 105-11

Philippines (Smart - Tagalog) 105-12

8552299304

Poland

ITFS

00-800-151-0052

-

Portugal

WWC

800-800-128

8552299304

Romania

WWC

0808-03-4288

8552299304

Russia (restricted coverage)

WWC

Russia 8^10-800-110-1011 Russia (Moscow) 363-2400 Russia (outside Moscow) 8^495-363-2400 Russia (outside St. Petersburg) 8^812-363-2400 Russia (St. Petersburg) 363-2400

(Note: The mark " ^ " appearing in some AT&T Direct® codes means "await second dial tone". )

8552299304

Saudi Arabia

WWC

1-800-10

8552299304

Serbia

-

-

-

Singapore

ITFS

800-110-2074

-

Slovenia

Europe Shared Collect

Dial Local Operator and ask them to connect you to 7045261128

7045261127

South Africa

ITFS

0800-992-887

-

Spain

ITFS- Combo

999-97-1251

-

Spain

DA- Combo

900-99-0011

8552299304

Sri Lanka

WWC

Sri Lanka (Colombo) 2-430-430 Sri Lanka (Outside Colombo) 112-430-430

8552299304

Sweden

ITFS- Combo

020-79-8389

-

Sweden

DA- Combo

020-799-111

8552299304

Switzerland

ITFS- Combo

0800-83-6085

-

Switzerland

DA- Combo

0-800-890011

8552299304

Taiwan

ITFS

00801-10-4471

-

Thailand

ITFS

001-80011-002-9735

-

Turkey

WWC

0811-288-0001

8552299304

UAE (United Arab Emirates)

WWC

U.A.E. 8000-021 U.A.E. (du) 8000-555-66 U.A.E. (Military-USO and cellular) 8000-061

8552299304

Ukraine

WWC

0-800-502-886

8552299304

United Kingdom

ITFS

0808-234-7287

-

USA

US Dialing Plan

8552299304

-

Venezuela

WWC

Venezuela (English) 0-800-225-5288 Venezuela (Spanish) 0-800-552-6288