Whistleblowing Policy

Objective

1. GuardWatch Security UK Ltd is committed to upholding the rights of our employees in relation to making qualified and protected disclosures (ie. Whistleblowing). This helps the Company operate with honesty and integrity, enabling any member of staff to inform management about concerns they may have regarding serious malpractice, fraud, or corruption. A culture of accountability is essential for preventing unethical conduct.

2. Workers are encouraged to resolve issues firstly internally in a safe and confidential environment. This procedure includes stages whereby the member of staff can receive advice about possible consequences before any formal Investigation commences. The procedure also balances the right of any individual to speak freely but also protect staff against false and malicious accusations.

3. This procedure is compatible with other security procedures and cannot be used for raising grievances about a personal employment situation.

4. This Policy does not form part of the Employment Contract and the Company may amend it at any time.

Definition

5. For the purposes of this Policy, “whistleblowing” is defined as the disclosure of information by an employee of confidential information relating to suspected wrongdoing or danger at work. This definition is sourced from the Public Disclosure Act 1998.

6. The disclosure must be a “qualifying disclosure”, meaning the worker must reasonably believe the disclosure is in the public interest and the disclosure communicates that the alleged wrongdoing is happening, has happened or will happen. Such disclosures may be non-exhaustively regarding:

• a criminal offence;

• a failure to comply with a legal obligation;

• a miscarriage of justice;

• a breach of health and safety regulations;

• damage to the environment;

• bribery;

• fraud or mismanagement;

• the deliberate concealing of information falling within any of the preceding categories.

7. If an employee has genuine concerns related to any suspected wrongdoing, you should report it following the procedures set out in this Policy.

8. Raising unfounded malicious allegations or initially disclosing information externally will be considered an abuse of this process and will be treated as a disciplinary offence.

Procedure

9. To constitute a “qualifying disclosure” within the scope of this Policy and whistleblowing legislation, the disclosure must be made in the correct way. The steps within this section should be followed.

Stage One: Informal Disclosure

10. If an employee has concerns, they should informally discuss the allegation with GuardWatch Security UK Ltd. If the allegation is against the Company, the discloser should discuss the allegation with the Managing Director.

11. This will be a confidential discussion, and the only record of the meeting will be a contemporary note made by the Company. The Discloser will be invited to read and initial this note. The Company will keep this note on file for twelve months. The Company will advise on whether the allegation complies with the definition of whistleblowing above and seek to ascertain the reason for the disclosure. Advice will be given on the procedure and implications should the Discloser wish to take the allegation further.

Stage Two: Formal Disclosure

12. If the employee wishes to pursue the matter further, they must provide the Company with a signed statement of the allegation. The Company will issue an acknowledgement. The Company will, within ten working days, formally discuss the matter in confidence with the appointed person, or other appropriate person. The discloser will be named at this confidential meeting. The result of this meeting will be:

(a) No further action required or

(b) Organisation Investigation will take place and the Investigating Officer decided.

13. The Discloser will be informed in writing of the result of this meeting.

Stage Three: Investigation

14. If an Investigation is required, the Company will formally request the Investigating Officer to commence this procedure. Unless required as part of the Investigation, the Discloser will not be named. The Investigation Report will be given to the officer who will re-convene the meeting from Stage Two to discuss the Report. The result of the meeting will be:

(a) No further action required or

(b) Disciplinary Hearing to be convened and the chair of the Disciplinary Hearing decided.

15. The Discloser will be informed by the Company in writing the result of this meeting. There will be no further formal communication with the Discloser.

Stage Four: Disciplinary Hearing

16. If a Disciplinary Hearing is required the officer will formally request HR to commence this procedure. Dependent on the result of this Hearing, appropriate action will be taken.

Assurances

17. We are committed to this Policy: all staff should be able to voice concerns openly. If any staff are concerned of reprisal as a result of raising such a concern, we can take additional measures to preserve confidentiality.

18. The law of whistleblowing requires staff do not suffer any detrimental treatment as a result of raising concerns. Detrimental treatment includes dismissal, disciplinary action, threats or unfavourable treatment connected with raising a concern. If an employee believes they have suffered such treatment, they should inform the Company immediately to discuss resolution. If the matter is not remedied, the formal Grievance Procedure should be triggered.

19. Even if the staff member turns out to be mistaken in their claim, this Policy applies. This does not extend to deliberate malicious falsified claims.