WHISTLEBLOWING Policy

CONTENTS

1. Introduction

2. Scope

3. Definitions

4. Whistleblowing procedure

INTRODUCTION

Skydive Ireland is dedicated to upholding the utmost standards of transparency, integrity, and responsibility. Central to this commitment is fostering an environment where staff and volunteers feel empowered to raise concerns without fear of retaliation. This policy aims to provide guidance to individuals who suspect malpractice or misconduct. It is not intended to challenge financial, or business decisions made by Skydive Ireland, nor should it be utilized to revisit matters that have already been addressed through safeguarding, complaint, disciplinary, or other established procedures.

SCOPE

This policy aims to empower employees and volunteers at Skydive Ireland to raise internal concerns at a senior level and to disclose information they believe reveals malpractice or impropriety. It is designed to address concerns that are in the public interest, including:

• Improper or unethical behaviour

• Dangers to health and safety or the environment

• Criminal activity

• Failure to comply with a legal obligation or statutes.

• Financial malpractice or impropriety or fraud

• Attempts to conceal any of these.

DEFINITIONS

Whistleblower - commonly referred to as someone who reports wrongdoing to an authority, typically within the authority's jurisdiction. Whistleblowers witness malpractice and should not face repercussions for disclosing information.

Protection - This policy aims to safeguard employees, volunteers, and other members at Skydive Ireland who report such concerns, provided they are made in good faith and directed to the appropriate individual. It's essential to note that this policy does not shield 13 MARCH 2024 individuals from internal disciplinary procedures or, in severe cases, legal action initiated by the accused parties.

Confidentiality - Skydive Ireland will handle all disclosures with confidentiality and sensitivity. The identity of the individual reporting the concern will remain confidential unless it impedes any investigation. However, their identity may be disclosed if their statement is required as part of the evidence.

Anonymous Allegations - While individuals are encouraged to attach their names to their disclosures, anonymous concerns may be considered at Skydive Ireland's discretion. Factors such as the severity of the issues raised, the credibility of the concern, and the likelihood of confirming it will be considered.

Unfounded Allegations - If an individual makes an allegation in good faith that isn't substantiated by subsequent investigation, no action will be taken against them. However, if someone makes malicious or vexatious allegations, and persists in doing so, disciplinary action may be pursued. The Public Interest Disclosure Act provides legal protection to employees who publicly disclose certain serious concerns against being dismissed or penalized by their employers. Skydive Ireland ensures that no staff member should feel disadvantaged for raising legitimate concerns.

WHISTLEBLOWING PROCEDURE

This policy delineates the procedure for lodging serious concerns with Skydive Ireland and ensuring they are appropriately addressed. Individuals approaching Skydive Ireland in good faith with information regarding wrongdoing will have their concerns handled with due care to all involved parties. If initial investigations reveal that the concerns fall under other Skydive Ireland policies, such as safeguarding or employment matters, the complainant will be informed accordingly, and the issue will be addressed under the relevant policy. Upon receipt of a malpractice concern, the staff member recording the concern must promptly report it to the Management Team. Investigations into malpractice will be conducted by the Management Team unless the complaint involves a member of that team. In such instances, the implicated member will be excluded from the investigation, or an impartial advisor, Emily Aucutt, will oversee the investigation. The investigation will not involve any individual against whom allegations are made, and information will only be shared with those deemed essential for the investigation's effectiveness. If evidence of criminal activity is uncovered, the investigating officer must notify the police. Skydive Ireland will ensure that any internal investigation does not impede a formal police inquiry. 13 MARCH 2024 Once a concern has been brought to the attention of the Management Team, the following steps should be adhered to:

• Comprehensive details and clarifications of the concern must be gathered and documented.

• Individuals implicated in the concern should be promptly notified. They are entitled to have a work colleague of their choice accompany them during any subsequent interviews or hearings. The Management Team may, at their discretion, permit an alternative representative, such as the individual's legal counsel.

• At this stage, the Management Team should consider involving the police if deemed necessary.

• The allegations will be thoroughly investigated by the Management Team, with assistance from other individuals or entities as deemed appropriate.

• A decision regarding the complaint's validity will be rendered by the Management Team. This decision will be outlined in a written report, detailing the investigation's findings and rationale for the judgment.

• The Management Team will determine appropriate actions to be taken.

• Those who raised the concern should be kept abreast of the investigation's progress and, if applicable, the outcome.

• In instances where the complaint involves a member of the Management Team, the impartial advisor may oversee the procedure.

• If individuals raising the concern remain dissatisfied with the outcome, they reserve the right to bring the concern to the impartial advisor for further consideration.

Any investigation will be conducted promptly, although more intricate matters may necessitate a lengthier and more comprehensive examination. In certain cases, particularly those involving child safety, it might be essential to escalate the issue to an external authority, such as the police. If this occurs, both the complainant and the accused party will be informed, unless prohibited by law or directed by the external authority.

Individuals raising genuine concerns with Skydive Ireland will not face any form of disadvantage or discrimination due to their disclosure. However, Skydive Ireland will take a serious stance and respond accordingly, including initiating disciplinary measures against responsible parties, if it is determined that the allegations were knowingly false or maliciously raised. Hence, individuals are encouraged to attach their name to any disclosure