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Our Policies & Credentials

Our Vision:

is to be instantly recognised as the leading company in workzone safety. Which means we want to be the brand that workers want protecting them and the company our customers can rely on.

Our Core Values are:

Innovative –
At the heart of everything we do is our ethos surrounding innovation and design focused on the continual improvement of our products and systems.

People first –
We put people first, whether the general public, on-site workers or any of our team.

Experts –
Our experience and expertise come from decades of working in the industry, in industrial design, product development, advanced scaffolding and in supply and distribution.

Supportive –
We aim to support each customer in any way we can, with any challenge and wherever needed.

Flexible –
As a company who puts customer experience and satisfaction at the top of the list, we believe in being flexible, understanding the complexities, challenges and demands of your world.

Policies we live by

We are committed worldwide to health and safety, innovation and service excellence.

It is the policy of vertemax™, as approved by the strategic health and safety committee that operations carried out by the Company are in accordance with the requirements of the Health and Safety at Work Act 1974 and associated Health Safety and Environmental Legislation, both in the spirit of the law and its legal obligations. The Company accepts its responsibilities towards its employees and any other person who may be affected by the work undertaken by the Company. Gary Taylor as the Managing Director has the overall responsibility for implementing and maintaining this policy through the use of the policy arrangements. His duties and that of other directors, senior managers, supervisors and employees are detailed in the Company's health and safety policy and supportive arrangements. If incidents are to be avoided, good working practices will be required. Therefore all company personnel shall familiarise themselves with their duties as detailed in the Safety arrangements. All employees have a part to play if high standards are to be achieved and maintained. The Company requests that all the work force and contractors take a pro-active role in improving health & safety performance through mutual commitment and co-operation at designated health and safety meetings. Managers with department health and safety responsibilities, along with the health and safety adviser, will monitor the operation of this policy. They will also be available to advise all employees on matters relating to health and safety. To support personnel in implementing the health and safety policy reference to industry best practice will be listed in this policy This statement is to be displayed in a prominent position at all designated locations. Gary Taylor Managing Director 21st January 2021
vertemax™ recognises that its activities impact upon the environment both through its routine internal operations, its infrastructural development and through its influence and effects on the wider community. It acknowledges a responsibility for, and a commitment to, protection of the environment at all levels. The Company will comply fully with environmental legislation and is in addition committed to continued efforts to: • Promote environmental management policies and practices at every level and in every division of the Company; • Increase awareness of environmental responsibilities among staff, customers and suppliers. • Minimise waste and pollution and develop and operate environmentally sound waste management procedures; • Continue to reduce the consumption of fossil fuels and to incorporate long term strategies for energy efficiency into planning and development; • Continue to encourage and facilitate modes of transport by employees which minimise environmental impact and to apply environmentally friendly principles to the operation of owned and hired in vehicles; • Reduce water consumption; • Promote a purchasing policy which will give preference, as far a practicable, to those products and services which cause the least harm to the environment; • Avoid wherever practical the use of environmentally damaging substances, materials and processes; • Maintain the grounds and buildings of the Company in an environmentally sensitive way, having regard to protection of local natural habitats and preservation of biological diversity; • Consider environmental factors in respect of the growth of the Company, seeking as far as is practical to reduce harmful environmental impacts and to integrate new developments into the local environment; • Work with other local, national and other agencies as appropriate to promote environmental policies; Progress in implementing this policy will be reviewed annually by the Management Committee, and reported to the Board. Gary Taylor Managing Director 21st January 2021
1.Purpose of this policy This policy sets out vertemax™ (“the company”) approach to equality and diversity. 2. Equality and diversity policy The company is committed to promoting equality and diversity and promoting a culture that actively values difference and recognises that people from different backgrounds and experiences can bring valuable insights to the workplace and enhance the way we work. The company is committed to providing equal opportunities throughout employment including in the recruitment, training and development of employees, and to pro-actively tackling and eliminating either direct or indirect discrimination. The practices, rights and obligations set out in this policy ensure that nobody working for the company is treated less favourably on the grounds of disability, gender reassignment, marital status, pregnancy or maternity, race, religion of belief, sexual orientation, work pattern, age, colour, nationality or any other aspects unrelated to their current and potential skills, aptitudes and abilities. All employees will be encouraged to develop their skills and fulfil their potential and to take advantage of training, development and progression opportunities in the company. 3. Scope and application of this policy This policy applies to current, former and prospective employees and workers. Company will work towards the following: a) Recruitment: Selection for employment at the company will be on the basis of aptitude and ability, ensuring that all staff in a position of authority and those staff who recruit, select and appraise staff are aware of the policy and adhere to its requirements. b) During employment: The benefits, terms and conditions of employment and facilities available to the company employees will be reviewed on a regular basis to ensure that all employees and workers receive fair and reasonable treatment free from favour or discrimination based on unwarranted prejudice. c) Promotion: All promotion decisions will be made on the basis of merit, and will not be influenced by any of the protected characteristics listed above. Promotion opportunities will be monitored to ensure equality of opportunity at all levels. Where appropriate, steps will be taken to identify and remove unnecessary or unjustifiable barriers to promotion. This policy applies to all conduct in the workplace and also to conduct outside of the workplace that is related to your work (e.g. at meetings, social events and social interactions with colleagues) or which may impact on the company’s reputation (e.g. the expression of views on social media, contrary to the commitments expressed in this policy, that could be linked to the company) 4.Responsibility All employees irrespective of their position within the organisation will have some measure of responsibility for the effective operation of this policy, with certain key staff being responsible for specific duties as follow: The Company shall: • Co-ordinate the provision of guidance and train to staff on Diversity and Equal Opportunities in employment • Adopt recruitment, training and employment practices, which are consistent with the spirit of the policy and promote awareness of the principals involved, particularly amongst those staff who are responsible for decision making in those areas All individual employees have the duty to: • Co-operate with any measure introduced to develop and uphold diversity and equal opportunity in a workplace • Desis from harassing, abusing or intimidating other employees on any grounds. • Resist to any pressure to discriminate, which is placed upon them by other employees. • Inform management if they know or suspect that discrimination is taking place in employment 5. Enforcement and redress All staff with decision making responsibilities are advised that, in legal terms, there may be individual rather than corporate liability if they are adjudged to be seriously deficient in their application of this policy, despite appropriate instructions. Any member of staff who bullies, harasses or discriminates against another employee, fails to co-operate with measures designated to promote equality and diversity, or induces others to practice unlawful discrimination, may be subject to disciplinary action. Any member of staff who feels that he or she has been bullied, harassed or discriminated against shall have recourse to the grievance procedures. The General Manager has overall responsibility for equality and diversity and in conjunction with the Company will ensure standards and procedures are maintained. Gary Taylor Managing Director 21st January 2021
vertemax™ is committed to protecting your personal data and handling it responsibly. This privacy policy explains how we use any personal information we collect about you whenever you interact with us, including when you use our website, when you correspond with us (such as email or over the phone) and also the data we may receive from third parties. What information do we collect about you? We collect information about you when you place an order for product or services, when you voluntarily complete customer surveys, provide feedback and participate in competitions. Below is a list of information we collect - Your name and contact details (phone number, job title, email address) - Your payment and address details - Your marketing preferences, including any consents you have given us - Your browser or device information - Information about your use of our websites - Your communications with us - Photos and video footage of you captured on out CCTV cameras or photos - Any other Information you provide Cookies Our website is using cookies. Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. Follow link for more information about cookies http://www.allaboutcookies.org/ Why vertemax™ processes information about you? Consent As an Individual you can opt-in to receive information about our product offers (for example by requesting It by email) We’ll provide this information to you by email, text, or phone. We also rely on your consent to process information about your use of our websites and social media sites, so that we can improve your browsing experience and deliver online advertising that is relevant to you. Legitimate Interests We process your personal data when necessary to pursue our legitimate interests: - Tailoring our websites and communications to understand your individual preferences - Monitoring, improving and protecting our products, content and services - Sending you some types of direct marketing, including email and post - Responding to your comments or complaints - Undertaking, or inviting you to take part in market research - Preventing, investigating and/or reporting fraud, terrorism, misrepresentation, security incidents or crime - Managing legal claims, compliance, regulatory and investigative matters - Processing job applications Contract We process your personal data when necessary for contractual reasons, such as to administer your account registration and competition entries and to provide products and services that you have requested. Legal obligations We are legally required to process your personal data in cases where we need to - Respond to certain requests by government or law enforcement authorities - Comply with local Council safety requirements to collect CCTV footage Who vertemax™ shares personal data with vertemax™ will not share your information for marketing purposes with any other companies. In processing your order, we may send your details to, and also use information from credit reference agencies and fraud prevention agencies as well as transport companies to deliver your order. Personal data transfers outside of the EEA The EEA includes all EU countries, as well as Iceland, Liechtenstein and Norway. Where your personal data is transferred to a country outside of the EEA and that country is not subject to an EU adequacy decision, we will ensure your data is protected by appropriate safeguards. Personal data is not shared with other companies outside the vertemax™ group. How long vertemax™ retains personal data We retain personal data for several years from the date of relevant transaction. This is to understand your purchasing preferences and to meet our legal and contractual obligations. Where you have asked us not to send you direct marketing, we keep a record of that fact to ensure we respect your request in the future Your Rights to withdraw consent and to object (including direct marketing) We would like to send you information and updates about our company, our products and services. If you have consented to receive marketing, you may opt out at a later date. You have a right at any time to stop us from contacting you for marketing purposes or to processing your data If you no longer wish to be contacted for marketing purposes, please let us know by sending us an email info@vertemax.co.uk, or opt out using the link in our newsletter. You can also opt out through the online preferences received as a weblink in our weekly newsletter. How to contact us and exercise your rights We will do our best to assist with any queries you have about your personal data. You can contact our Data Protection Officer at any time using the contact details below. When you do so, please provide your full name, your preferred contact information, and a summary of your query. info@vertemax.co.uk Telephone 01227 711 072 Gary Taylor Managing Director 21st January 2021
We are delighted to inform our customers that our Quality Management Systems have met the high standards set out by the International Organisation for Standardisation. "The ISO 9001:2015 standard demands a high degree of leadership commitment. Our decision to work towards ISO 9001 accreditation demonstrates our unwavering commitment to delivering and maintaining a high quality service to our clients together with our ongoing investment in technology, infrastructure, new systems, and improved processes and procedures. Furthermore, the accreditation encouraged greater, positive engagement amongst colleagues who have all shared in this success and will continue to contribute to the company’s further achievements in the knowledge that we have excellent Quality Management Systems" says Gary Taylor, CEO at vertemax Group. Each year, an external Audit is carried out by a third party to ensure our systems are maintained and any non-conformances are noted for correction. “Outstanding thought and preparation have been invested in order to ensure compliance with the requirements of BS EN ISO 9001: 2015, prior to the Stage 1 Audit. The Organisation should be highly commended for the diligence displayed in their preparation work and for Top Management’s commitment to the continual improvement of a Quality Management System in their Organisation.” Jonathan Dean at QMS UK
1. Purpose The purpose of this policy is to establish controls to ensure compliance with all applicable anti-bribery and corruption regulations, and to ensure that the Company’s business is conducted in a socially responsible manner. 2. Policy statement Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal or a breach of trust. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage. It is our policy to conduct all of our business in an honest and ethical manner. We take a zero- tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery. We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by the laws of the UK, including the Bribery Act 2010, in respect of our conduct both at home and abroad. Bribery and corruption are punishable for individuals by up to ten years' imprisonment and a fine. If we are found to have taken part in corruption, we could face an unlimited fine, be excluded from tendering for public contracts and face damage to our reputation. We therefore take our legal responsibilities very seriously. 3. Scope 3.1 Who is covered by the policy? In this policy, third party means any individual or organisation you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties. This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as employees in this policy). This policy covers: • Bribes; • Gifts and hospitality; • Facilitation payments; • Political contributions; • Charitable contributions. 3.2 Bribes Employees must not engage in any form of bribery, either directly or through any third party (such as an agent or distributor). Specifically, employees must not bribe a foreign public official anywhere in the world. 3.3 Gifts and hospitality Employees must not offer or give any gift or hospitality: • which could be regarded as illegal or improper, or which violates the recipient’s policies; or • to any public employee or government officials or representatives, or politicians or political parties; or • which exceeds £20 in value for each individual gift or £100 in value for each hospitality event (not to exceed a total value of £400 in any financial year), unless approved in writing by the Managing Director. Employees may not accept any gift or hospitality from our business partners if: • it exceeds £20 in value for each individual gift or £100 in value for each hospitality event (not to exceed a total of £400 in any financial year), unless approved in writing by the Managing Director; or • it is in cash; or • there is any suggestion that a return favour will be expected or implied. If it is not appropriate to decline the offer of a gift, the gift may be accepted, provided it is then declared to the employee’s manager and donated to charity. We appreciate that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered. Within these parameters, local management may define specific guidelines and policies to reflect local professional and industry standards. Where this policy requires written approval to be given, the Company Secretary shall put in place a process to maintain a register of all such approvals. 3.4 Facilitation payments and kickbacks Facilitation payments are a form of bribery made for the purpose of expediting or facilitating the performance of a public official for a routine governmental action, and not to obtain or retain business or any improper business advantage. Facilitation payments tend to be demanded by low level officials to obtain a level of service which one would normally be entitled to. Our strict policy is that facilitation payments must not be paid. We recognise, however, that our employees may be faced with situations where there is a risk to the personal security of an employee or his/her family and where a facilitation payment is unavoidable, in which case the following steps must be taken: • Keep any amount to the minimum; • Create a record concerning the payment; and • Report it to your line manager. In order to achieve our aim of not making any facilitation payments, each business of the Company will keep a record of all payments made, which must be reported to the Managing Director, in order to evaluate the business risk and to develop a strategy to minimise such payments in the future. 3.5 Political Contributions We do not make donations, whether in cash or kind, in support of any political parties or candidates, as this can be perceived as an attempt to gain an improper business advantage. 3.6 Charitable contributions Charitable support and donations are acceptable (and indeed are encouraged), whether of in- kind services, knowledge, time, or direct financial contributions. However, employees must be careful to ensure that charitable contributions are not used as a scheme to conceal bribery. We only make charitable donations that are legal and ethical under local laws and practices]. No donation must be offered or made without the prior approval of the compliance manager. All charitable contributions should be publicly disclosed. 4. Your responsibilities You must ensure that you read, understand and comply with this policy. The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy. You must notify the Managing Director or the Company Secretary as soon as possible if you believe or suspect that a conflict with or breach of this policy has occurred, or may occur in the future. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with other workers if they breach this policy. 5. Record-keeping We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties. You must declare and keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review. You must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with our expenses policy and specifically record the reason for the expenditure. All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept "off-book" to facilitate or conceal improper payments. 6. How to raise a concern You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries or concerns, these should be raised with your line manager OR the Managing Director or through the confidential helpline. 7. What to do if you are a victim of bribery or corruption It is important that you tell the Company Secretary or the confidential helpline as soon as possible if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity. 8. Protection Employees who refuse to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Managing Director immediately. If the matter is not remedied, and you are an employee, you should raise it formally using the company’s Grievance Procedure. 9. Training and communication Training on this policy forms part of the induction process for all new employees. All existing employees will receive regular, relevant training on how to implement and adhere to this policy. In addition, all employees will be asked to formally accept conformance to this policy on an annual basis. Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter. 10. Who is responsible for the policy? The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. The Managing Director has primary and day-to-day responsibility for implementing this policy, and for monitoring its use and effectiveness and dealing with any queries on its interpretation. Management at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training on it. 11. Monitoring and review The Managing Director will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption. All employees are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing. Employees are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the Managing Director. This policy does not form part of any employee's contract of employment and it may be amended at any time. Gary Taylor Managing Director 21st January 2021
The primary objective of vertemax™ is to ensure that we provide services that consistently meet, if not exceed, customer requirements and expectations. To assist in achieving this objective we installed a quality management system consistent with the stringent requirements BS EN ISO 9001 : 2015 which gives due consideration to the regulatory requirements of both Health and Safety and the Environment. It is the company policy to ensure that all employees are fully cognisant of the requirements of the Quality Management System and are appropriately trained and supplied with the resources to ensure its continued effectiveness. The System including this Policy Statement is continually monitored and reviewed for its applicability and effectiveness through a programme of internal auditing, management review and the analysis of performance against defined objectives. These objectives include the development of a more comprehensive dialogue with our suppliers and customers, for mutual benefit. Expanding the dialogue within the company to ensure a full understanding of our objectives and performance and the opportunity for input at all levels. Gary Taylor Managing Director 21st January 2021
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. VertemaxTM has a zero tolerance approach to any form of modern slavery and will continue to review and update its policies and processes to ensure there is no opportunity for these offences to take place. This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that vertemax ltd has taken during this financial year and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain. This statement applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors and suppliers. About Us vertemax™ was incorporated in May 2010 and specialises in innovation, development and provision of specialist work zone safety systems and products for collective protection, personal protection, access and service solutions. Vertemax™ sales and hires products designed to protect people. It puts people first, whether the general public, on-site workers or any of our team. Currently vertemax™ directly employs more than 30 people in the UK and Canada combined. The company has an annual turnover less than £36 million. Our Policies and Due diligence This statement reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls. Vertemax TM operates and maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become our supplier. This due diligence includes supplier approval process and a research to ensure that particular organisation has never been convicted of offences relating to modern slavery. To identify and assess potential risk areas of our business and reduce risk of slavery vertemax™ also: • Operate strict procurement processes requiring suppliers to comply with all applicable laws and standards including those which relate to modern slavery act. • Expect our suppliers to have suitable policies and processes in place within their business to prevent any form of modern slavery, human trafficking and child labor and to communicate these policies to their suppliers. • Continuously monitor and review the assurance information from our suppliers and partners and follow up where relevant. • Include appropriate terms in our contract documentations • Reserve the right to terminate the contracts at any time should any cases of modern slavery came to light. People To ensure we conduct business in ethical and transparent manner and to identify and mitigate risks of modern slavery, vertemax™ maintains and promotes the following internal policies which are accessible to all staff. • Health & Safety Management Policy • Equality and Diversity Policy • Anti-Bribery And Corruption Policy We ensure all employees know they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals. Vertemax™ always checks its employees have the Right to Work in the UK or Canada. Each employee work under terms agreed and signed in employment contract agreement. Wages is paid only directly to the employee bank account, no cash transactions are permitted. Training We regularly conduct training for our procurement/buying teams and inform every employee so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our business or supply chain. To minimise risks, our procurement team is advised only to purchase from a reputable company. Risks Vertemax™ assessed the risk of modern slavery in its business and supply chain and consider it very low. Nevertheless, these results indicate low risk, we will continue to monitor and assess all areas of the business to prevent the risk of modern slavery from happening. Approval for this statement This statement policy was prepared for financial year ending 31 December 2020 and was approved by the director of vertemax™. Gary Taylor Managing Director 21st January 2021
Do you have something on your mind? We are here to listen! We uphold a healthy and open culture, where each employee has a responsibility to comply with current regulations and act ethically. We can solve many situations by talking to each other straight after they occur. Sometimes things can happen that require a completely different approach. Regardless, it is important for us that problems or more serious issues are revealed so that we, as an organisation, can act. In more serious cases such as forms of misconduct, or where there is a danger to life and limb, it is important that these come to light early on. As an employee or partner, you are a key factor in this process. If you have a feeling that something is not as it should be, it is important for us that you can highlight this in a safe manner. This is why we offer you two different options to have your say, through our internal reporting system or whistleblowing using an external independent operator. What can you report? If you feel you need to raise an issue, this is reason enough to report it. It is important for us as an organisation to live up to our values. We therefore need help discovering when these are not complied with so that we can clearly show where to draw the line and what values are at stake. An example of a problem you can report is when an individual in our organisation or a partner company violates our code of conduct, which defines what we as a company stand for, our values and how we do business. Other likely issues can be more serious misconduct and offences such as fraud, embezzlement, corruption, breaches of trust, information theft, corporate espionage and data breaches. If our guidelines are not helpful, you can use the following questions to decide on what steps to take. • Is there an issue that you think violates what we stand for and how we describe how we should carry out our work duties? • Do you consider what has happened to be justifiable from a legal or ethical perspective? • Would our business come into disrepute if the situation became known to the general public? • How would you view the issue if you were a customer or another stakeholder? 1. Internal reporting As soon as you experience misconduct or something irregular, you should contact either your line manager or their manager. If you feel that you cannot trust any of these, for example if you suspect that they are involved, you should first raise the issue with management. Do you feel in doubt about raising the issue with a manager? Then you should use the whistleblowing system. 2. Whistleblowing Sometimes, it may not be appropriate to raise an issue through internal reporting processes because of what has to be reported. For this reason, we provide access to a whistleblowing system. This is an important safety valve for both us and our employees. That is why we use an external independent operator, Whitepaper Advisors. Through their Trumpet whistleblowing system, you can anonymously and confidentially report serious misconduct committed by management or other key individuals in the company. Refer to our whistleblowing policy. What can be reported? According to Swedish law, there are restrictions on what may be handled in a whistleblowing system. Therefore, using the whistleblowing system, you may not report issues that do not constitute serious misconduct, such as general dissatisfaction with how the company is run, with management, salaries or other staff issues. Incidents committed by individuals who are not part of management or who are not key persons in the company may not be dealt with in the whistleblowing system either. Reports submitted through the Trumpet whistleblowing system must be based on concrete suspicions. Proof against the suspect is not required, but accusations cannot be made maliciously or with the knowledge that the accusations are false. False or malicious accusations are a serious breach of the employment contract. Read more in our whistleblowing policy. Who can submit a report? Anyone who represents our organisation in any way can submit a report in the whistleblowing system. This includes board members, all employees (permanent employees, probationary employees, fixed-term employees, full-time and part-time employees), trainees and hired staff (agent staff). Customers, suppliers, consultants and partner employees are also given access to the system. How case management works Trumpet is an external whistleblowing service that provides a secure process where you, as a whistleblower, can be completely anonymous. If you do not include your name in the report yourself, it is not possible to see who submitted the case in the system. Trumpet has been developed based on the highest standards of confidentiality and security. Trumpet complies with the EU’s GDPR directive and the EU directive protecting whistleblowers, as well as Swedish legislation regarding special protection against reprisals for employees who blow the whistle on serious misconduct. The system is the brainchild of Whitepaper Advisors, a company with solid experience of investigating and helping organisations deal with misconduct. Browse to www.trumpet-whistleblowing.eu for more information. Process, step by step: 1. Complete anonymity is guaranteed when reporting in Trumpet. Whistleblowers are not disclosed unless they wish to make themselves known. 2. When you report an event in the system, an encrypted case is created in the whistleblowing system for which you receive a unique encryption key. 3. An external independent case manager at Whitepaper Advisors always processes your case and makes a first assessment of your report. Only you and your case manager can access your case using your own encryption key. 4. The process can be speeded up if you actively make the choice to disclose your identity to the independent case manager. In so doing, you and your case manager administrator can have an effective and secure dialogue — no one else will find out who you are. (It is also possible for you to choose to disclose your identity to the organisation.) 5. A recommendation is submitted to our organisation’s whistleblowing committee once your case manager has made an assessment. This committee, in turn, decides how the case is to be taken forward and what measures are to be taken. If your report concerns anyone in our committee, they will be excluded by Whitepaper Advisors before the recommendation and report are submitted. Those involved in the committee are outlined in our whistleblowing policy. 6. Whitepaper Advisors’ case manager notifies you of the current case status and the committee’s decisions through a secure Trumper login. How to report Your report is submitted to Trumpet using a web link, by phone or by post. Reports can be submitted 24/7 both in Swedish and English. A report in Trumpet is always handled with anonymity maintained and with the utmost confidentiality. If you want to ensure your activity is not tracked, you should choose a private computer or mobile phone and access the service from a network you trust, for example your home network. • Submit a report via the Trump website by browsing to www.trumpet-whistleblowing.eu on any device (computer, tablet or mobile phone) and then entering our organisation code below to login to the whistleblowing page. • Reporting by phone or post means a process that is somewhat different from the online channel. Read more on Trump’s website about what applies for each reporting option. Trumpet whistleblowing: www.trumpet-whistleblowing.eu Use our organisation code: MIHWB Trump’s website provides clear guidelines about the entire process. It has a FAQ section describing each step. Document Midway Holding Policy Visselblåsning (SWE) Midway Holding Whistleblower Policy Whistleblowing reporting Trumpet whistleblowing Use our organisation code: MIHWB

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