Whistleblowing Policy

This policy is intended for serious concerns about actual or suspected wrongdoing.

Examples may include:

• fraud, theft, corruption, or bribery;
• serious breaches of law or regulation;
• financial misconduct or deliberate falsification of records;
• serious conflicts of interest or abuse of position;
• modern slavery, human trafficking, forced labour, or serious exploitation;
• serious discrimination, harassment, or abuse;
• serious breaches of our policies or professional standards;
• conduct that creates a serious risk to people's safety, rights, or wellbeing;
• deliberate concealment of any of the matters above.

The list is not exhaustive. If you are unsure whether a concern falls within this policy, you may raise it and we will determine the appropriate way to handle it.

Not every workplace or commercial disagreement is a whistleblowing matter.

Routine complaints, performance issues, disagreements about a search, or dissatisfaction with a commercial decision should normally be raised through the appropriate business or management channel.

However, a concern should not be excluded simply because it also involves an employment, commercial, or professional dispute if it involves serious wrongdoing or a significant risk of harm.

Anyone who has a genuine concern about conduct connected to Kelson may raise it.

This includes:

• employees and contractors;
• candidates;
• clients;
• suppliers and service providers;
• business partners; and
• other people who interact with Kelson.

You do not need to be certain that wrongdoing has occurred. A reasonable and good-faith concern is sufficient.

Concerns should be reported to:

contact@kelsonsearch.com

When possible, please provide enough information for us to understand:

• what happened;
• who was involved;
• when and where it occurred;
• why you believe it may constitute wrongdoing; and
• any relevant documents or evidence.

You may raise a concern even if you do not have all of this information.

We will handle whistleblowing concerns with appropriate confidentiality.

Information will be shared only with people who need it to assess, investigate, or respond to the concern, subject to applicable law.

We will respect requests for confidentiality where reasonably practicable.

However, confidentiality cannot always be guaranteed. In some circumstances, information may need to be disclosed to relevant authorities or other parties in accordance with the law.

Kelson does not tolerate retaliation against anyone who raises a genuine concern in good faith.

Retaliation may include dismissal, disadvantage, threats, intimidation, harassment, exclusion, or other adverse treatment because a person has raised a concern or participated appropriately in a review or investigation.

A concern that is raised honestly will not result in disciplinary action simply because it is ultimately found to be unsubstantiated.

Knowingly making a false or malicious allegation, however, may be treated as misconduct.

We will assess concerns promptly and determine the appropriate response based on their nature and seriousness.

Depending on the circumstances, this may include:

• seeking additional information;
• conducting an internal review or investigation;
• involving appropriate external advisers;
• taking corrective or disciplinary action;
• suspending relevant activity or relationships; or
• referring the matter to a relevant authority where required or appropriate.

Not every concern will require a formal investigation.

We will seek to handle each matter proportionately, fairly, and without unnecessary delay.

Where an investigation is appropriate, we will seek to establish the relevant facts objectively.

People involved in a concern will be treated fairly.

A person who is the subject of an allegation will have an appropriate opportunity to respond, subject to the needs of the investigation and applicable law.

We will not assume that an allegation is true simply because it has been reported.

Nothing in this policy is intended to prevent a person from reporting suspected wrongdoing to a regulator, law enforcement agency, or other competent authority where they have a legal right or obligation to do so.

Where appropriate, we may cooperate with relevant authorities.

We will keep appropriate records of whistleblowing concerns and actions taken in response, subject to applicable privacy and data protection requirements.

Information will be retained only for as long as reasonably necessary for legitimate business, legal, or regulatory purposes.

Speaking up should not require courage beyond what a professional environment should reasonably ask of a person.

We would rather hear a genuine concern early than discover serious wrongdoing later.

Our standard is simple:

Speak up in good faith. We will listen.