Whistleblowing Policy 1 Purpose Mercury is fully committed to “doing the right thing” and conducting business with honesty, fairness and openness. Our people should feel confident and able to speak up if something is not right, and be protected from retaliation or disadvantage. This policy sets out the processes and principles Mercury has in place to encourage you to report suspected wrongdoing. It covers what wrongdoing is, how you should report suspected wrongdoing, how those concerns will be listened to and dealt with by Mercury, and what rights and protections Mercury will give you as a whistleblower. This policy applies to you if you are an employee (past or present), director or officer, secondee, contractor or a volunteer of Mercury, including its subsidiaries and Mercury controlled Joint Ventures.
2 What is “wrongdoing” and what should you do about it? Mercury wants to know about wrongdoing that may be happening in its business. Wrongdoing could include any act or omission or course of conduct by a person or people which you think is:
dangerous and / or a risk to the health or safety of you or Mercury’s customers, employees or contractors or to the public; likely to cause significant damage to the environment; fraudulent or against the law; getting in the way of the prevention, investigation or detection of criminal offences by Mercury’s customers, employees, suppliers or competitors; sexual harassment, bullying or discriminatory to you, any of your colleagues, or to Mercury’s customers or to the public; or putting at risk the assets, brand or reputation of Mercury.
If you suspect that wrongdoing is occurring or has occurred, you are expected to report it to Mercury. Once you report the wrongdoing, the process Mercury will follow and your rights and protections as a whistleblower will be as set out in this policy. If you volunteer additional information in support of a concern reported by someone else, you will also be entitled to the protections set out in this policy, provided that you volunteer that information to the General Counsel or otherwise in accordance with this policy.
3 Protection and support for whistleblowers It is in Mercury’s best interests to be made aware of any actual or suspected wrongdoing by, or within, its business. If you raise a genuine concern about a wrongdoing, we are committed to supporting you and doing our best to make sure you do not experience any retaliation from Mercury. Mercury will:
offer People Experience support to any person that reports an actual or suspected wrongdoing; maintain confidential information that might identify you (see below); strictly prohibit any behaviour that discourages someone from reporting a wrongdoing, or that could amount to retaliatory action or less favourable treatment from anyone at Mercury. Any person that engages in such behaviour may face disciplinary or other action; and not take any civil, criminal or disciplinary proceedings against you for making the disclosure.
To qualify for these protections the report must be made in accordance with the procedures set out in this policy and in good faith. The protections in this policy will not apply if you report a wrongdoing knowing it to be false or in bad faith. Protected Disclosures (Protection of Whistleblowers) Act 2022 You may also be protected under the Protected Disclosures (Protection of Whistleblowers) Act 2022 (Act) if the wrongdoing you are disclosing is serious. If your disclosure is a protected disclosure under the Act, you will have statutory immunity from any civil and criminal proceedings in relation to the disclosure.
Whistleblowing Policy | Approved by the Board 24 February 2025 | Page 1 of 3