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Whistleblowing Policy

Introduction

Redgate is committed to conducting our business with honesty and integrity and we expect all Redgate employees to maintain the highest level of standards.

Scope

This policy covers:

  • All Redgate employees & officers (Redgaters), consultants, contractors, sub-contractors, volunteers, interns, agency workers and other business representatives.
  • Third Parties i.e., any individual or organization, and includes, but is not limited to, active and potential clients, customers, suppliers, business contacts, agents, advisors, government, and public bodies.

    • Policy

    We believe that, for the vast majority of the time, Redgate (through Redgaters and those who work with us and on our behalf) maintains very high standards and acts in line with Redgate’s values. However, we recognize the possibility that there will be occasions when this is not the case. The aim of this policy is to provide a mechanism for reporting, investigating, and remedying any wrongdoing or suspected wrongdoing within Redgate.

    The law recognizes that in some circumstances it may be appropriate for you to report your concerns to an external body, such as a regulator. However, we encourage you to seek advice before reporting a concern to anyone external.

    What is Whistleblowing?

    Whistleblowing is the reporting of suspected wrongdoing or dangers in relation to our business activities. This includes bribery, facilitation of tax evasion, fraud or other criminal activity, miscarriages of justice, health and safety risks, damage to the environment and any breach of legal or professional obligations.

    How to raise a concern

    Given our culture of transparency and feedback within Redgate we hope that in many cases you will be able to raise any concerns with your manager. However, in instances where you prefer not to raise it with your manager, you should consider speaking to the Head of HR or General Counsel. If you feel that this is also not appropriate, you can use our secure and compliant whistleblowing platform Whistlelink. See below the description of the report:

    Your report should contain the following:

    • The type of suspect wrongdoing or dangers in relation to Redgate business activities you wish to report.
    • Where it has taken place.
    • When it happened, providing the time and date and anything recurring.
    • Any documentation you may have to support your report, or alternatively where the documentation exists.
    • Details of any other action you may have taken in relation to the report.

    External Reporting

    The Whistlelink platform also allows for external reporting, and it is possible to report externally to a competent authority.

    How the Whistlelink Platform Works

    • Only the following authorized individuals will have access to this platform, namely, Redgate's Head of HR, General Counsel and Compliance Manager.
    • If you wish to submit a concern, you click this link to access the Whistlelink platform to report your concern.
    • All messages are secure, and no data is shared.
    • Once the report is uploaded:
      • A confirmation code will be shared on the reporting screen.
      • You, the reporter will be provided with a case number.
      • You will need to keep a copy of this code to keep up to date with progress.
      • Authorized Redgate individuals will receive alerts on all new cases, new messages, any document uploaded and any regulated deadline.
      • Dialogue takes place between the case manager and the reporter.
      • Investigation takes place internally until a satisfactory conclusion is reached.

    Protection and Support for Whistleblowers

    • Redgate offers Whistlelink to report anything you may feel is relevant (see What Is Whistleblowing?, above) and that you don’t feel able to raise with either your line manager, the Head of People team, or the General Counsel.
    • Your report is submitted via a dedicated webpage, from any type of device and in any language.
    • You remain completely anonymous when you report unless you voluntarily provide personal information. There is no obligation to provide any personal information if you do not want to. (no IP addresses can be identified).
    • If, however, you would prefer to identify yourself rather than report anonymously, then Redgate is committed to ensuring that no employee is subjected to any detriment, or victimized, by reason of having made a protected disclosure in good faith. We will investigate the matter appropriately and take the appropriate action.
    • There may also be occasions, based on the seriousness of the issue, and if it is a criminal offense that we need to report the activity to the relevant authorities, which may mean that you are required to identify yourself.

    Monitoring and Review

    This policy will be monitored, and procedures reviewed, and may be updated from time to time to ensure they remain adequate.

    If you have any questions or concerns about anything in this policy, please contact whistleblowing@red-gate.com