WHISTLEBLOWING POLICY

Purpose

All organisations face the risk of things going wrong or of unknowingly harbouring illegal or unethical conduct.

RSD Vantage is committed to doing business with honesty and integrity and encouraging openness and accountability.

Employees and those working under the company’s control are often the first to realise that there is something wrong within the organisation however they may feel that speaking up would be disloyal to the business itself.

RSD Vantage believes those working under our control should feel free to report any incidents of malpractice or suspected wrongdoing without fear of suffering retribution provided any such reports are based on genuine concerns and are without malice or made in bad faith.

All those working under the control of RSD Vantage are encouraged to raise genuine concerns about possible improprieties in the conduct of our business at the earliest opportunity.

Scope

This policy applies to all employees and contractors of RSD Vantage.

This policy has been approved by the Managing Director and relates to any suspected malpractice and wrongdoing concerning matters such as:

• Financial impropriety and fraud.
• Failure to comply with legal or regulatory obligations, such as health and safety obligations.
• Criminal offences e.g. theft.
• Bribery and corruption.
• Breaches of RSD Vantage’s Business Ethics and Conduct Policy.
• Actions that are intended to conceal any of the above.

Principles

• The following principles apply to the operation of this policy:
• All concerns raised will be treated fairly and properly.
• RSD Vantage operates a zero-tolerance policy to any form of retaliation against anyone raising a genuine concern.
• If you have a reasonable belief that something inappropriate has happened and you act in good faith in making a disclosure, you will be protected. This assurance does not extend to someone who maliciously raises a matter they know is untrue.
• Anyone making a disclosure will retain their anonymity unless they agree otherwise however, please be aware that the ability to investigate anonymous disclosures will be limited.
• Secure your operations.

Process

If any employee believes reasonably and in good faith that improprieties exist in the workplace, then he or she should report them immediately to the Director.

The concern should be made orally or in writing, describing the incident(s) as fully as possible. All concerns raised will be viewed seriously and treated as confidential.

Provided there is sufficient evidence to support the allegation/concern, a full investigation will be conducted to establish whether malpractice has occurred.

Workers who have raised a concern will be informed of who is handling the matter and how they can be contacted.

RSD Vantage will carry out an initial review of the information received and will then determine what the most appropriate course of action is. We will contact you following our initial review and update you about the next stages of the process.

We will give as much feedback as we can without any infringement on the duty of confidence owed by us to someone else. Workers’ identities will not be disclosed without prior consent. Where concerns cannot be resolved without revealing the identity of the worker raising the concern, we will enter into dialogue with the worker concerned in the first instance to discuss whether and how we can proceed.

Anyone who retaliates against a whistle-blower (who reported in good faith) will be subject to formal disciplinary action.