Whistleblowing Channel

GInnova is committed to maintaining the highest standards of ethics, integrity, and compliance in all our business activities. This Whistleblowing Policy provides a secure and confidential channel for employees, contractors, suppliers, customers, and other third parties to report concerns about improper conduct, potential wrongdoing, or regulatory breaches.

This policy operates in compliance with the UK Public Interest Disclosure Act 1998 (PIDA) and the EU Whistleblower Protection Directive, ensuring protection for individuals who make protected disclosures in good faith.

You should report concerns about any of the following matters:

• Criminal Offences: Including fraud, theft, corruption, bribery, money laundering

• Regulatory Breaches: Violations of FCA regulations, AML requirements, data protection laws

• Financial Misconduct: Accounting irregularities, false financial reporting, tax evasion

• Health and Safety: Failures that endanger health and safety of employees or the public

• Environmental Damage: Breaches of environmental regulations and sustainability commitments

• Breach of Legal Obligations: Failure to comply with contractual duties, employment law, or other legal requirements

• Cover-Ups: Attempts to conceal any of the above matters

• Professional Misconduct: Inappropriate behaviour that brings the company into disrepute

Confidential Reporting Channels:

Internal Reporting:

• Email: info@ginnova.co.uk (encrypted)

• Phone: +44 7520 655417 (ask for confidential reporting)

• Post: Confidential marking, GInnova, 128 City Road, London, EC1V 2NX

• Online form: Secure form available on our website

External Reporting Options:

• Financial Conduct Authority (FCA): consumer.queries@fca.org.uk

• Information Commissioner's Office (ICO): dpa@ico.org.uk

• Health and Safety Executive (HSE): www.hse.gov.uk/contact

• Serious Fraud Office (SFO): report@sfo.gov.uk

• Prescribed Persons under PIDA: Relevant regulatory bodies

Anonymous Reporting:

You may make reports anonymously, but providing contact details helps us investigate thoroughly and provide feedback on actions taken.

To help us investigate your concern effectively, please provide:

• Details of the concern: What happened, when, where, and who was involved

• Evidence: Any documents, emails, or other evidence you have available

• Witnesses: Names of anyone who may have relevant information

• Your relationship: How you are connected to the matter being reported

• Previous actions: Whether you have reported this elsewhere

• Contact details: If you wish to receive feedback (optional)

Please provide as much detail as possible, even if you are not certain about all aspects of your concern.

GInnova provides comprehensive protection for whistleblowers:

Legal Protections:

• Protection under PIDA from dismissal, discipline, or detriment for making protected disclosures

• No contractual limitation on making protected disclosures

• Protection from civil action by the company for making the report

Company Commitments:

• No disciplinary action for good faith whistleblowing

• Confidentiality of your identity unless required by law

• Protection from harassment or victimization

• Support during and after the investigation process

• Right to be accompanied at any meetings about your report

Important Notes:

• Protection applies only to reports made in good faith

• Malicious or false reports are not covered by these protections

• Deliberately false information may result in disciplinary action

All reports are handled according to the following procedure:

Step 1: Initial Assessment (Within 5 working days)

• Acknowledge receipt of your report

• Initial assessment of the allegations

• Decision on whether formal investigation is required

• Assignment to appropriate investigating officer

Step 2: Investigation (Within 30 working days)

• Gathering of evidence and witness statements

• Analysis of the issues raised

• Assessment of regulatory or legal implications

• Preparation of investigation report

Step 3: Decision and Action (Within 45 working days)

• Review of investigation findings

• Decision on appropriate action

• Implementation of remedial measures

• Report to senior management and board where appropriate

Step 4: Follow-up (Within 60 working days)

• Feedback to the whistleblower (where possible and appropriate)

• Monitoring of implemented actions

• Review of whistleblowing process effectiveness

We are committed to maintaining confidentiality throughout the whistleblowing process:

• Your identity will be kept confidential unless you consent otherwise

• Information will only be shared on a 'need to know' basis for investigation purposes

• Secure storage and handling of all whistleblowing communications

• Limited access to whistleblowing records and evidence

• Confidentiality may be breached only where required by law or for health and safety protection

• Special protection for electronic communications and data

Depending on the investigation findings, appropriate actions may include:

• Disciplinary Action: Against employees found responsible for misconduct

• Process Improvements: Changes to policies, procedures, or controls

• Regulatory Reporting: Notification to relevant regulatory authorities

• Legal Action: Involvement of law enforcement where criminal activity is identified

• Restitution: Measures to rectify any harm caused

• Training: Additional compliance training for relevant staff

• Policy Updates: Changes to company policies and procedures

• Third-party Action: Action against suppliers, partners, or contractors

All actions are documented and reviewed for effectiveness.

GInnova operates a strict zero-tolerance policy towards retaliation:

• Any form of retaliation against whistleblowers is prohibited

• Allegations of retaliation will be investigated promptly

• Disciplinary action will be taken against anyone found to have retaliated

• Support systems are available for whistleblowers who experience retaliation

• Regular monitoring of workplace climate to detect potential retaliation

• Training for managers on identifying and preventing retaliation

If you need additional support, these organisations can help:

• Protect (UK): whistleblowing charity providing free advice - 020 3117 2520

• Public Concern at Work: Professional whistleblowing support - 020 7404 6609

• Advisory, Conciliation and Arbitration Service (ACAS): Employment law advice - 0300 123 1100

• Citizens Advice: Free legal advice - 03444 111 444

• Trade Unions: If you are a union member, contact your representative

• Legal Aid: May be available for qualified individuals

This Whistleblowing Policy is reviewed annually to ensure it remains effective and compliant with current legislation. Key metrics monitored include:

• Number and nature of reports received

• Time taken to investigate and resolve concerns

• Outcomes and actions taken

• Feedback from whistleblowers

• Effectiveness of protection measures

• Regulatory requirements and best practices

The policy is approved by the Board of Directors and overseen by our compliance function.

For whistleblowing matters, contact:

GInnova

Attn: Whistleblowing Officer

128 City Road, London, EC1V 2NX

United Kingdom

Secure Email: info@ginnova.co.uk

Confidential Phone: +44 7520 655417

Website Secure Form: https://ginnova.co.uk/whistleblowing

For urgent matters requiring immediate attention, please mark your communication as 'URGENT - CONFIDENTIAL'.