Uniroyal Global Engineered Products, Inc.
Uniroyal Global Engineered Products, Inc. wishes to encourage a free and open culture in which employees can raise concerns about breaches or failures. Employees who raise genuine concerns under this policy will not be subjected to any form of detriment or disadvantage as a result of having raised their concerns.
This policy explains forth what employees should do if they suspect wrongdoing.
This policy applies to all employees of Uniroyal Global Engineered Products, Inc. and all of its subsidiaries, including Uniroyal Engineered Products, LLC and Uniroyal Global Limited, which are collectively referred to as the “Company.”
A whistleblower is an employee who knows or suspects that wrongdoing is occurring within the Company and alerts his employer or the relevant external body about the situation. This is called making a disclosure.
A disclosure is different from a grievance. The person making the disclosure is usually not personally affected by the wrongdoing. Consequently, the person making the disclosure may not have a personal interest in the outcome of any investigation into the person’s concern. The employee is simply trying to alert others. On the other hand, a grievance is a claim that the employee believes that he or she has been improperly treated.
Examples of situations in which it might be appropriate for an employee to make a disclosure include (but are not limited to):
- a criminal offense
- damage to the environment
- a failure to comply with a legal obligation
- a breach of health and safety legislation or regulations
- financial irregularities
- a miscarriage of justice
- information tending to show that any of the above (or a similar matter) has been, is being or is likely to be deliberately concealed.
An employee should make a disclosure in good faith when they employee has a genuine belief that wrongdoing has occurred, is occurring or is likely to occur. There is no need for the employee to prove the alleged breach or failure; a reasonable suspicion will suffice; i.e., where the employee reasonably believes that the disclosure is substantially true.
If any disclosure is made in bad faith (for instance, in order to cause disruption within the Company) or concerns information that the employee does not believe is true, or if the disclosure is made for personal gain, then such a disclosure will constitute a disciplinary offence for purposes of the Company’s disciplinary policies and may constitute gross misconduct, for which summary termination or dismissal is the sanction.
Any employee who makes a valid disclosure may be protected by local or national law from any detriment in relation to any allegations that the employee makes. If the employee does not comply with this policy (for example, if the sole or principal reason for the disclosure is to pursue a personal vendetta), the statutory protection may well be lost.
3.1 Action to Be Taken by the Employee
If an employee knows or suspects that some wrongdoing is occurring, has occurred, or is likely to occur within the Company, he or she should raise the matter immediately with the relevant manager; that, is, the manager of the area concerned. If the employee does not know whom to approach, or if the relevant manager is involved with the concern, the employee should talk to his or her line manager, the Vice President – Human Resources or the Human Resources Officer or Company counsel.
3.2 Action to Be Taken by the Manager or other Person to Whom the Matter is Referred
Any manager or officer who is informed by an employee of potential wrongdoing must take immediate action to investigate the situation. If requested, the manager or officer will take every reasonable step to maintain the anonymity of the employee making the disclosure; however, the employee may be required to attend an investigatory meeting and or a disciplinary hearing as a witness.
The employee making the disclosure will be kept informed of any investigation that is taking place and will be informed of the outcome of the investigation. It might not always be appropriate to provide details of any action taken to the employee.
3.3 Alerting relevant External Bodies
In the first instance, an employee should talk to a manger about potential wrongdoing. If the employee does not feel that internal disclosure is appropriate or he or she is not satisfied with the outcome of an internal disclosure, he or she should communicate the concern to the Company’ legal counsel or to the Chairman of the Audit Committee of Uniroyal Global Engineered Products, Inc. The contact information of the Chairman of the Audit Committee is as follows:
John E. Scates
Mail: c/o Secretary
Uniroyal Global Engineered Products, Inc.
1800 2nd Street, Suite 970
Sarasota, Florida 34236
Direct electronic mail: email@example.com.
If the employee is still not satisfied that the employee’s concern is being handled appropriately, the employee may contact a relevant governmental agency to express the employee’s concern. The agency may be the Securities and Exchange Commission, the Environmental Protection Agency (EPA) or the Occupational Health and Safety Administration (OSHA) in the U.S. or the Health and Safety Executive, the Financial Services Authority or the Environment Agency in the U.K.
The media are not a relevant external body. No employee should contact the media with allegations about the Company. This in itself will be considered a disciplinary offense for the purposes of the company’s disciplinary policies and may constitute gross misconduct, for which summary termination or dismissal is the sanction.
3.4 Retaliation not Permitted
The Company will not permit retaliation of any kind against any employee for any disclosure made in good faith under this policy.
3.5 Retention of Records
The Company will retain for seven (7) years as a part of its corporate records all documents relating to any such complaints or concerns.
Adopted by the Board of Directors of Uniroyal Global Engineered Products, Inc.: June 8, 2017
Adopted by the Board of Managers of Uniroyal Engineered Products, LLC: June 9, 2017
Adopted by the Board of Directors of Uniroyal Global Limited: June 12, 2017