Whistleblowing Policy

*(Making a disclosure in the public interest)*

1. Our commitment

Vyce is committed to openness and accountability. Part of that is a route for people to raise serious concerns without fear of reprisal, independently of line management where they need it.

The Public Interest Disclosure Act 1998 protects workers against dismissal or detriment for making a protected disclosure. This policy explains how to raise a concern and what we'll do about it.

This policy is for people who believe they've discovered malpractice. It isn't a route to challenge business decisions, and it shouldn't be used to revisit matters already dealt with under grievance or disciplinary procedures.

2. What this covers

Raise a concern where you reasonably believe one of the following has happened, is happening, or is likely to happen:

• A criminal offence
• Failure to comply with a legal obligation
• A miscarriage of justice
• Danger to anyone's health and safety
• Damage to the environment
• Sexual harassment, whether it has occurred, is occurring, or is likely to occur
• Deliberate concealment of any of the above

Fraud, bribery, facilitation of tax evasion, data protection breaches and unethical conduct all fall within these.

3. Protection

This policy protects anyone who raises a concern where they reasonably believe the information tends to show one of the matters above, and that disclosing it is in the public interest.

You don't need to be certain you're right. You don't lose protection if the concern turns out to be mistaken, as long as your belief was reasonable. You don't need evidence, and it isn't your job to investigate first.

Protection applies whether or not the disclosure is made in good faith. Where a tribunal finds a disclosure wasn't made in good faith, compensation may be reduced by up to 25 per cent.

Knowingly false or malicious allegations aren't protected and may lead to disciplinary action.

We won't retaliate against anyone who raises a concern, and we'll treat any attempt to do so as a disciplinary matter.

4. Confidentiality

We treat disclosures confidentially. We'll keep your identity confidential so far as that doesn't frustrate the investigation. Be aware the investigation itself may reveal the source, and you may need to give a statement.

5. Anonymous disclosures

We'd rather you gave your name, because anonymous concerns are harder to investigate. We'll still consider them, weighing how serious the issue is, how credible it is, and whether it can be corroborated.

6. How to raise a concern

• Your line manager, for less serious matters
• A Director, who will investigate or appoint an investigating officer
• The Chief Operating Officer, where the concern involves a Director
• The Chief Executive, where the concern involves the Chief Operating Officer
• Confidential reporting line — 0203 868 6303
• Email — hello@vyce.io

You can bypass line management entirely and go straight to the Chief Executive.

Whoever receives a concern must pass it to the appropriate investigating officer as soon as reasonably possible. If there's evidence of criminal activity the investigating officer will inform the police, and we won't let an internal investigation hinder a police one.

7. Timescales

The nature of these concerns makes fixed timescales impossible, but we'll investigate as quickly as the quality of the investigation allows.

The investigating officer will acknowledge your concern in writing, keep you updated if the investigation is prolonged, and write to you with the outcome and the action proposed.

8. How we investigate

• Get full details and clarification
• Tell the person the concern is about as soon as practicable, and tell them they may be accompanied at any interview
• Consider whether auditors or the police should be involved
• Investigate fully
• Reach a judgement, set out in a written report with findings and reasons
• Pass the report to the Chief Executive, who decides what action to take
• Where the concern is substantiated, invoke disciplinary or other appropriate procedures
• Keep you informed, and tell you the outcome where appropriate

If you aren't satisfied your concern is being handled properly, raise that in confidence with the Chief Operating Officer or Chief Executive.

9. Going outside the company

If the investigation doesn't substantiate your concern and internal procedures are exhausted, you keep the right to disclose to a prescribed person. The Government maintains a current list at gov.uk, which includes the Health and Safety Executive, HMRC, the Information Commissioner and the Financial Conduct Authority.

You can also get independent advice from the whistleblowing charity Protect, on 020 3117 2520.

We won't use confidentiality or settlement agreements to stop anyone making a protected disclosure, and any clause attempting to do so is void.

10. Review

Reviewed annually.