The Lamson Paragon Group of Companies Whistleblower Policy

1.   Purpose

The Lamson Paragon Group of Companies ("The Company") is committed to maintaining the highest standards of integrity and ethical behavior. This Whistleblower Policy is intended to provide a safe and confidential environment for employees, contractors, suppliers, and other stakeholders to raise concerns about any misconduct, unethical behavior, or any other wrongdoing within The Company.

2.   Scope

This policy applies to all employees, contractors, suppliers, customers, and other stakeholders of The Company. It covers any disclosure of information regarding potential misconduct, unethical behavior, illegal activities, or any other concerns that could adversely affect The Company, its employees, or the public.

3.   Reportable Conduct

Reportable conduct under this policy includes, but is not limited to:

• Fraud, theft, or other forms of dishonesty.
• Corruption or bribery.
• Harassment or discrimination.
• Violations of health and safety regulations.
• Environmental damage.
• Any other illegal activities.
• Any other conduct that violates The Company’s policies or ethical standards.

4.   Reporting Procedure

If you have reasonable grounds to suspect that any misconduct or wrongdoing has occurred or is occurring, you are encouraged to report your concerns through the following channels:

Email:This email address is being protected from spambots. You need JavaScript enabled to view it.

All reports will be treated confidentially and will be taken seriously. Anonymous reports are also accepted; however, providing your contact details may assist in the thorough investigation of your concerns.

5.   Protection of Whistleblowers

The Company is committed to ensuring that whistleblowers are protected from any form of retaliation, discrimination, or harassment as a result of reporting concerns in good faith. Any form of retaliation against a whistleblower will not be tolerated and will be subject to disciplinary action.

6.   Investigation

All reports of misconduct or wrongdoing will be promptly and thoroughly investigated. The investigation process will involve:

• Acknowledging receipt of the report (if contact details are provided).
• Assessing the report to determine the appropriate course of action.
• Conducting a fair and impartial investigation.
• Taking appropriate corrective action based on the findings of the investigation.

7.   Confidentiality

All reports and the identity of the whistleblower (if disclosed) will be kept confidential to the fullest extent possible, consistent with the need to conduct a thorough investigation and comply with legal requirements.

8.   Roles and Responsibilities

• Whistleblower Protection Officer (WPO): Responsible for overseeing the implementation of this policy and ensuring the protection of whistleblowers.
• Investigation Team: Responsible for investigating reports of misconduct and providing findings to the relevant authority within The Company.
• Employees and Stakeholders: Responsible for reporting any suspected misconduct or wrongdoing and cooperating with any investigations.

9.   False Reports

While this policy encourages the reporting of genuine concerns, individuals who knowingly make false or malicious reports may be subject to disciplinary action.

10.   Review and Amendment

This policy will be reviewed regularly and may be amended from time to time to ensure its effectiveness and compliance with applicable laws and regulations.

11.   Contact Information

For questions or further information about this policy, please contact:

Whistleblower Protection Officer

The Lamson Paragon Group of Companies

12.   Approval

This policy has been approved by the Board of Directors and is effective as of 1st January 2024.

The Lamson Paragon Group of Companies