The OHI Group Speak Up Reporting Channel provides a safe, secure and confidential way to raise a concern, seek guidance, or report suspected misconduct relating to any actual or potential breach of applicable law, regulation, or OHI Group policies governing business practices, ethical conduct or corporate governance, including the OHI Group Code of Ethics and Business Conduct (CEBC). OHI Group is committed to maintaining the highest standards of integrity, transparency and accountability. We encourage everyone to speak up if something does not seem right.
The OHI Group Speak Up Policy establishes how concerns can be raised safely and explains how reports will be managed fairly, confidentially and objectively. Anyone who raises a concern honestly and in good faith will be protected from retaliation, discrimination, victimisation or any other adverse treatment.
The OHI Group Speak Up Reporting Channel exists to ensure that:
• employees, former employees, directors, contractors, consultants, agency workers, suppliers, customers, business partners and other stakeholders can safely report suspected misconduct, unethical behaviour or breaches of law or OHI Group policy;
• all reports are assessed and investigated appropriately;
• the confidentiality of the reporting individual and anyone named in a report is protected wherever reasonably practicable; and
• OHI Group continues to promote an ethical culture built on integrity, accountability and responsible business conduct.
• The Speak Up Reporting Channel is operated using an independent and secure platform designed to protect confidentiality, privacy and information security. Information submitted through the platform is encrypted and securely stored.
Reports may be submitted anonymously where permitted by local law. Anonymous reporting allows secure communication between the reporting individual and those responsible for reviewing the report through a confidential secure inbox.
The Speak Up Reporting Channel should be used to report any actual or suspected breach of law, regulation, the OHI Group Code of Ethics and Business Conduct, or any OHI Group corporate policy. Examples include concerns relating to:
• Workplace harassment
• Sexual harassment
• Bullying
• Discrimination
• Victimisation
• Other workplace misconduct
• Conflicts of interest
• Bribery
• Corruption
• Fraud
• Theft
• Abuse of authority
• Procurement misconduct
• Gifts and hospitality breaches
• Breaches of the Code of Ethics and Business Conduct
• Breaches of any OHI Group policy or procedure
• Data privacy breaches
• Cybersecurity incidents
• Misuse of company systems
• Information security breaches
• Intellectual property violations
• Unauthorised disclosure of confidential information
• Accounting irregularities
• Financial misconduct
• Tax-related misconduct
• Money laundering
• Terrorist financing
• Breaches of sanctions or export controls
• Competition or anti-trust violations
• Regulatory non-compliance
• Serious health and safety concerns
• Environmental breaches
• Security incidents
• Human rights concerns
• Modern slavery
• Forced labour
• Child labour
• Environmental misconduct
• Human rights violations
• Breaches of ESG commitments
• Community concerns
Requests for guidance regarding ethical or compliance matters before taking action.
No.
The Speak Up Reporting Channel is not intended for routine employment matters such as performance reviews, pay discussions, leave requests or other day-to-day HR issues. These should be addressed through the appropriate People & Culture processes.
Similarly, customers, suppliers and business partners should not use the Speak Up Reporting Channel for routine commercial enquiries, contractual disputes or customer service matters. These should be directed to the relevant OHI Group business or customer service representative.
• To submit a report, select “Submit a Report” on the OHI Group Speak Up portal.
• The reporting process consists of five simple steps:
• Select the country where the incident occurred.
• Provide details of the concern, including what happened, when it occurred and any supporting information.
• Choose whether to submit the report anonymously or provide your contact details.
• Create a password for your secure inbox, which enables confidential communication regarding your report.
• Submit your report and retain your unique Case Reference Number.
The secure inbox allows investigators to request additional information and provide updates while maintaining confidentiality.
Protecting individuals who speak up is a fundamental principle of the OHI Group Speak Up programme.
Where anonymous reporting is permitted by law:
• you are not required to disclose your identity;
• reports are encrypted and securely stored;
• communications take place through a confidential secure inbox;
• only authorised investigators have access to report information.
If you choose to remain anonymous, avoid including information that could unintentionally identify you.
All reports submitted through the Speak Up Reporting Channel will normally be acknowledged within seven calendar days, where contact details or a secure inbox are available.
If you submitted your report anonymously, you should regularly log into your secure inbox using your Case Reference Number and password to check for updates or requests for additional information.
Where appropriate, OHI Group aim to provide feedback on the progress of an investigation within three months of acknowledging receipt of the report.
The level of information shared will depend on legal, confidentiality and investigation requirements. In some cases, detailed outcomes cannot be disclosed, but OHI Group will seek to keep reporting individuals appropriately informed throughout the process.
