Whistleblowing Policy
Apex Grove Distribution Ltd ("Apex Grove") encourages anyone who has concerns about wrongdoing connected with our business to speak up. We will treat concerns seriously, protect those who raise them in good faith, and act on what we find. Apex Grove is part of the Earthe group.
Who Can Raise a Concern
Employees, casual workers, subcontractors, suppliers, clients, community members and anyone else connected with our work.
What to Report
- Bribery, corruption, fraud or procurement irregularities.
- Breaches of sanctions or trade compliance rules.
- Modern slavery, child labour or human trafficking.
- Health and safety dangers or unreported incidents.
- Environmental harm, including pollution, spills or unpermitted abstraction.
- Discrimination, harassment or bullying.
- Misuse of personal data.
- Any other breach of law or our policies, or deliberate concealment of any of the above.
How to Report
Email connect@apexgrove.ke. Please mark your message "Confidential – Whistleblowing". Include as much detail as you can: what happened, when, where and who was involved. You do not need proof, only a reasonable belief. You may report anonymously, although this can make it harder to investigate and give you feedback.
Employees may also raise concerns with their line manager, unless the manager is involved.
How We Handle Reports
- We acknowledge reports promptly, normally within seven working days.
- Reports are reviewed by senior leadership independent of the matter raised.
- We investigate fairly and confidentially, and take appropriate action.
- Where appropriate, we tell the reporter the outcome, subject to legal and confidentiality limits.
- Where required, we refer matters to the relevant authorities, such as the Ethics and Anti-Corruption Commission, NEMA, or the Directorate of Occupational Safety and Health Services.
Protection and Confidentiality
We will keep your identity confidential as far as possible. We do not tolerate retaliation, including dismissal, demotion, harassment or loss of work, against anyone who raises a concern in good faith. Retaliation is itself a disciplinary matter. Deliberately false or malicious reports may also lead to disciplinary action.
External Reporting
Nothing in this policy prevents anyone from reporting concerns directly to the competent authorities, as permitted by law, including the Bribery Act 2016.
Review
This policy is reviewed at least annually.
Last reviewed: November 2026
Signed:
Gruffald Salter, CEO
Apex Grove Distribution Ltd