Whistleblower Policy

Purpose

Genuine Way Limited is committed to maintaining a workplace that encourages integrity, transparency, and accountability. This Whistleblower Policy provides employees, contractors, consultants, and other stakeholders with a safe and confidential way to report concerns about unethical, illegal, or improper conduct without fear of retaliation.

Scope

This policy applies to all employees, contractors, consultants, vendors, and other stakeholders of Genuine Way Limited It covers reports related to:

  • Fraud or financial irregularities
  • Bribery and corruption
  • Breaches of legal or regulatory requirements
  • Discrimination, harassment, or other workplace misconduct
  • Health and safety violations
  • Environmental damage
  • Any other unethical or improper conduct

Reporting a Concern

1. Confidentiality

  • All reports will be treated with the utmost confidentiality.
  • The identity of the whistleblower will only be disclosed on a need-to-know basis or if required by law.

2. How to Report

Concerns can be reported through the following channels:

  1. Direct Manager: Employees are encouraged to report concerns to their immediate manager.
  2. Human Resources (HR): Reports can also be made directly to the HR department.
  3. Legal Compliance Department: legal@genuineway.co.uk.
  4. Anonymous Reporting: Reports can be made anonymously via info@genuineway.co.uk.

Investigation Process

  1. Acknowledgment: Upon receiving a report, the whistleblower will be acknowledged (if not anonymous) within Five [5] business days.
  2. Assessment: The report will be reviewed to determine the scope and nature of the alleged issue.
  3. Investigation: An impartial investigation will be conducted by the Whistleblower Officer or an appointed team.
  4. Outcome: Appropriate action will be taken based on the findings, and the whistleblower will be informed of the outcome (if identity is known).

Protection Against Retaliation

Genuine Way Limited strictly prohibits retaliation against whistleblowers who report concerns in good faith. Retaliation includes, but is not limited to:

  • Termination or suspension
  • Harassment or discrimination
  • Negative performance evaluations
  • Any other adverse action

False Allegations

Employees who knowingly make false or malicious allegations may be subject to disciplinary action. However, employees who report concerns in good faith, even if the concerns turn out to be unfounded, will not face any consequences.

Responsibilities

1. Legal Compliance Department

  • Ensures reports are investigated promptly, fairly, and confidentially.
  • Provides guidance and support to whistleblowers.

2. Managers

  • Encourage open communication and a culture of transparency.
  • Support employees who report concerns and prevent retaliation.

3. Employees

  • Report any concerns promptly and in good faith.
  • Cooperate fully with investigations.

Policy Review

This Whistleblower Policy will be reviewed annually to ensure compliance with applicable laws and regulations and to maintain best practices.

Last Updated: March 2025