Whistleblower Policy for PlumbSpark Ltd

Document Classification: INTERNAL

Version: v1.0

Date Issued: 19/03/2025

Note: This document is uncontrolled when printed.

Introduction

PlumbSpark Ltd is committed to fostering a culture of transparency, integrity, and accountability. We recognize the importance of providing a safe, confidential, and effective means for employees and associated individuals to report concerns about misconduct or unethical behaviour. This Whistleblower Policy is designed to encourage and protect those who report genuine concerns in good faith.

Purpose

The purpose of this policy is to:

  1. Encourage employees and stakeholders to report any suspected wrongdoing or unethical behaviour.

  2. Provide a clear framework for reporting concerns and ensure these are addressed promptly and effectively.

  3. Protect whistleblowers from retaliation, discrimination, or victimization resulting from their disclosures.

Scope

This policy applies to all employees, officers, directors, contractors, consultants, trainees, volunteers, interns, and any other individuals associated with PlumbSpark Ltd. It covers all types of misconduct, including but not limited to:

  • Fraud, theft, or financial irregularities

  • Bribery and corruption

  • Health and safety violations

  • Environmental damage or non-compliance

  • Breaches of company policy or legal obligations

  • Any other unethical or unlawful conduct

Reporting Procedure

  1. Raising a Concern:

    • Concerns should be reported as soon as possible to allow for timely investigation and resolution.

    • Employees can report their concerns to their immediate manager or directly to the compliance manager if they feel uncomfortable speaking to their manager.

  2. Confidential Helpline:

    • PlumbSpark Ltd provides a confidential helpline, available to all employees, as an alternative reporting channel. This ensures that those who wish to remain anonymous can report their concerns without fear of identification.

  3. Written Reports:

    • Concerns can also be submitted in writing to the compliance manager. Written reports should include as much detail as possible to facilitate a thorough investigation.

Investigation Process

  1. Acknowledgment:

    • Upon receiving a report, the compliance manager will acknowledge receipt and provide an estimated timeline for the investigation.

  2. Evaluation:

    • The compliance manager will assess the concern to determine its validity and the appropriate course of action.

  3. Investigation:

    • An impartial investigation will be conducted, involving relevant parties as necessary, while maintaining confidentiality to the greatest extent possible.

  4. Outcome:

    • The whistleblower will be informed of the investigation's outcome, provided this does not infringe on privacy rights or legal obligations.

Protection and Support

  1. Protection from Retaliation:

    • PlumbSpark Ltd is committed to ensuring that no whistleblower faces retaliation, discrimination, or harassment as a result of raising a concern in good faith. Any such behaviour will be subject to disciplinary action.

  2. Confidentiality:

    • All reports and investigations will be handled discreetly and sensitively. The identity of the whistleblower will be protected unless disclosure is required by law.

  3. Support:

    • Whistleblowers will have access to support and counselling services, if needed, throughout the process.

Responsibilities

  1. Board of Directors:

    • The Board has overall responsibility for ensuring the effectiveness of this policy and for fostering a culture of openness and transparency.

  2. Compliance Manager:

    • The compliance manager is responsible for managing the whistleblowing process, conducting investigations, and ensuring reports are handled appropriately.

  3. Managers and Supervisors:

    • All management personnel are responsible for supporting this policy, encouraging openness, and ensuring employees feel safe to raise concerns.

Monitoring and Review

The effectiveness and implementation of this policy will be regularly reviewed by the compliance manager. Feedback from employees and stakeholders is encouraged to continuously improve the whistleblowing process.

 

 

This Whistleblower Policy is a vital component of PlumbSpark Ltd's commitment to ethical conduct and corporate responsibility. Employees are encouraged to familiarize themselves with this policy and utilize the established channels to report any concerns they may have.

Authorized by: Nilesh Ladva

Position: Compliance Officer

Date: 19/03/2025

Company: PlumbSpark Ltd