Whistleblowing Policy

Speaking up about wrongdoing

Introduction

Universal App Company is committed to conducting business with honesty and integrity. We expect all employees, contractors, and associates to maintain high standards of conduct. This policy provides a framework for raising concerns about wrongdoing in a safe and confidential manner.

Purpose

This policy aims to:

  • Encourage reporting of genuine concerns about malpractice
  • Provide clear guidance on how to raise concerns
  • Reassure individuals that they can raise concerns without fear of reprisal
  • Ensure concerns are properly investigated
  • Demonstrate our commitment to transparency and accountability

Scope

This policy applies to all employees, contractors, consultants, agency workers, and anyone working on behalf of Universal App Company.

What Should Be Reported

This policy covers concerns about conduct that is:

  • Illegal or constitutes a criminal offence
  • A breach of legal or regulatory obligations
  • Dangerous to health and safety
  • Damaging to the environment
  • A miscarriage of justice
  • A breach of company policy or professional standards
  • Fraud, bribery, or corruption
  • Modern slavery or human trafficking
  • Abuse of power or authority
  • Deliberate concealment of any of the above

How to Raise a Concern

Step 1: Initial Reporting

Concerns can be raised through the following channels:

  • Your line manager (if you feel comfortable doing so)
  • Human Resources
  • A senior manager or director
  • The designated Whistleblowing Officer
  • Our confidential whistleblowing email: whistleblowing@universalappco.com

Step 2: Information to Include

When raising a concern, please provide:

  • The background and history of the concern
  • Names of individuals involved
  • Dates and times of events
  • Supporting evidence (if available)
  • Any other relevant information

Concerns can be raised anonymously, though this may limit our ability to investigate fully or provide feedback.

Protection from Retaliation

We will not tolerate any form of retaliation or victimization against individuals who raise genuine concerns in good faith. This includes:

  • Dismissal or threat of dismissal
  • Harassment or bullying
  • Discrimination
  • Disciplinary action
  • Any other detrimental treatment

Any retaliation will be treated as a serious disciplinary matter.

Confidentiality

We will treat all disclosures confidentially and will not reveal your identity without your consent, unless:

  • We are required to do so by law
  • The information needs to be disclosed to conduct a proper investigation
  • The information needs to be disclosed to prevent harm

Even in these circumstances, we will inform you before disclosing your identity.

Investigation Process

When a concern is raised:

  1. We will acknowledge receipt (unless the concern was raised anonymously)
  2. We will assess the concern and decide on the appropriate action
  3. An appropriate person will investigate the matter promptly and thoroughly
  4. We will keep you informed of progress (where possible)
  5. We will take appropriate action based on the findings
  6. We will provide feedback on the outcome (where appropriate and possible)

Timescales

We aim to:

  • Acknowledge concerns within 5 working days
  • Complete investigations within a reasonable timeframe (typically 4-6 weeks)
  • Provide updates if investigations take longer

External Reporting

While we encourage internal reporting, you may report concerns to external bodies if:

  • You have already raised the concern internally without satisfactory response
  • You reasonably believe that evidence will be concealed or destroyed
  • The concern is of an exceptionally serious nature

External bodies may include:

  • Relevant regulatory authorities
  • Law enforcement agencies
  • Prescribed persons under the Public Interest Disclosure Act 1998

Malicious or False Allegations

This policy is intended for genuine concerns raised in good faith. Deliberately false or malicious allegations may result in disciplinary action.

Support

Raising concerns can be stressful. We provide support through:

  • Designated support person during investigations
  • Employee Assistance Program
  • Reasonable adjustments to working arrangements if needed

Monitoring and Review

We monitor the operation of this policy, including:

  • Number and nature of concerns raised
  • Investigation outcomes
  • Effectiveness of the process
  • Any instances of retaliation

This policy is reviewed annually and updated as necessary.

Contact Information

Whistleblowing Officer:
Email: whistleblowing@universalappco.com

Last Updated: January 2024

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