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\\        Whistleblowing Policy

You can download Whistleblowing Policy VG-LEG-POL-004, V. 4, Dec 2023 here.


Venterra Group Plc and, by extension, its subsidiary Balltec Ltd (the Venterra Group, Balltec, we, us) are committed to an open, ethical and safe business environment where its workforce feel able to speak up.

Who is covered by this Policy?

This policy applies to shareholders, employees, former employees, agency workers, contractors, officers and board members of the Venterra Group.

Matters covered by this Policy

We welcome information being brought to the attention of management about unsafe or unethical matters you think are or may be taking place within, or which threaten the interests of, the Venterra Group, its workforce or the public such as:

▪ fraud
▪ malpractice (e.g., financial irregularities, corruption, bribery, dishonesty)
▪ criminal offences
▪ failure to comply with law
▪ miscarriages of justice
▪ dangers to health and safety
▪ dangers to the environment
▪ unethical conduct e.g., bullying, harassment
▪ covering up wrongdoing
▪ a breach of the Venterra Group Code of Conduct.

Note this procedure is not to be used to address concerns about a personal employment situation, such matters should be raised through the standard employment grievance procedure.


If you have a concern or enquiry you can:

▪ Raise the matter with your line manager
▪ Contact another manager in your team or company, the Venterra Director of Human Resources or the Venterra Group General Counsel
▪ Contact the Executive Chair of Venterra Group Plc.

Concerns can be raised orally or in writing, see below for contact details.

Where it may not be appropriate to contact someone internally, you should contact EthicsPoint via the details below. You may remain anonymous, although please be mindful that anonymity may impede an investigation. EthicsPoint is administered by an independent company, is available 24 hours a day, 7 days a week and can accommodate calls in 200+ languages.

The Group Director of HR and Group General Counsel are responsible for investigating all reports. Reports will be acknowledged within 7 days and feedback provided to the reporter within 3 months to allow for a thorough investigation.

Usually, you will meet with the person investigating the matter. If you prefer to remain anonymous, you may correspond or speak by phone with the person investigating the matter. You will be informed as far as possible about the outcome of the investigations, subject to the rights of any third parties which must be respected.

Ideally, you will feel able to make a disclosure internally within Venterra or to EthicsPoint. If you are dissatisfied with the way in which your concern has been addressed or you reasonably believe that an internal report is futile or that the matter is an emergency, you may raise the issue with the appropriate external regulatory body (e.g. external auditors, the UK Health and Safety Executive or the relevant authority in the applicable jurisdiction).


You can raise concerns about matters within Venterra in confidence and without fear of reprisals.

Matters raised under this procedure will be kept confidential to the greatest extent possible consistent with law and good business practices. The identity of a whistle-blower will not be disclosed without explicit consent to anyone beyond those dealing with the report, unless this is necessary and proportionate in the
context of the investigation.

Venterra will not penalise or tolerate retaliation directed against anyone raising concerns or making allegations in good faith. Retaliation is any form of reprisal, direct or subtle. It may take the form of threats, intimidation, an attempt to identify someone who speaks up, exclusion or humiliation. Any act or threat of retaliation will be treated as a serious violation of our Code of Conduct and may constitute misconduct meriting disciplinary action. 

Protection is provided for whistle-blowers who bring matters of public interest to the attention of their employers or outside bodies as set out in applicable law. 

If you think that you or someone you know has experienced retaliation, contact any of the resources listed below.

Speak Up Resources

Group Director of HR
John Leighton-Jones
+44 (0) 20 3154 6357
[email protected]

Group General Counsel
David Crowther
+44 (0) 20 3154 6370
[email protected]

Executive Chair, Venterra Group Plc
Ayman Asfari
+44 (0) 20 3154 6350
[email protected]

* Dial Access Code first (where applicable) and then enter Phone Number


United Kingdom



Code of Conduct VG-LEG-COD-001
Anti-Bribery and Corruption Policy VG-LEG-POL-001

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