This statement of policy should be read in conjunction with Shaftesbury’s Corporate Responsibility Policy and provides a summary of Shaftesbury's Whistleblowing Policy. A revised Policy was approved by the Board in May 2007.

Shaftesbury is committed to the highest standards of behaviour in the conduct of every aspect of its business, and expects Directors, staff and other organisations employed by the Company (together known as "employees") to adhere to this commitment.

There may be circumstances in which a Director or member of staff becomes aware of decisions or activities carried out in the Company's name which are in conflict with the Company's commitment to high standards of business behaviour. Such conflicts may arise as a result of breaches of internal rules or the Company's Corporate Responsibility Policy, criminal offences or breaches of civil law, and the deliberate concealment of any malpractice.

Where an employee believes, in good faith, there has been a breach of good behaviour, they should report the matter of concern to the Chief Executive. Where the employee feels this may be inappropriate due to a conflict of interest, they should communicate their concerns either to the Chairman or the Senior Independent Director.

Communication of concerns of inappropriate decisions or activities may be verbal or in writing but should be supported by appropriate evidence to allow such matters to be properly investigated and action taken as considered appropriate. The person to whom such concerns have been raised is required to fully investigate such matters and bring them to the attention of the Board, with recommendations for remedial action. Individuals communicating concerns may require a written response to the matters they have raised.

It is the policy of Shaftesbury to encourage the reporting of inappropriate business behaviour. Individuals raising legitimate concerns of activities which are detrimental to Shaftesbury's reputation will not be subject to any adverse sanction unless there is evidence that they have acted with malicious intent.

Approved by the Board
May 2007