Autologyx Whistleblowing policy

1. Introduction

1.1 Autologyx is committed to maintaining the highest standards of honesty, integrity, and transparency. This whistleblowing policy is designed to encourage employees and other stakeholders to report concerns about unethical or unlawful conduct without fear of reprisal.

2. Purpose & Scope

• Provide a framework for reporting suspected misconduct or wrongdoing.
• Protect whistleblowers from retaliation.
• Ensure concerns are investigated thoroughly, impartially, and confidentially.

2.2 This policy applies to all employees, contractors, suppliers, and other stakeholders associated with Autologyx.

3. Definition of Whistleblowing

3.1 Whistleblowing is the act of reporting suspected or actual wrongdoing within the organisation. This includes, but is not limited to:

• Fraud or financial misconduct.
• Breaches of laws, regulations, or organisational policies.
• Information security or data protection concerns.
• Discrimination, harassment, or bullying.
• Health and safety violations.
• Environmental damage.
• Any unethical or unlawful behaviour.

3.2.    This policy does not cover personal grievances, such as disputes about employment terms, which should be addressed through the grievance procedure.

4.Reporting Mechanism

4.1 How to Report

4.1.1 You can report concerns through the following channels:

• Directly to your Line Manager, CCO, CTO of Head of Information Security via any channel (email, Slack, etc.) if you feel comfortable doing so.
• Email: privacy@autologyx.com
• Form: Whistleblowing Form

4.2. Confidentiality

4.2.1. All reports will be treated with the utmost confidentiality. The identity of the whistleblower will not be disclosed unless required by law or necessary for the investigation.

4.2.2. Those receiving whistleblowing concerns uphold a Code of Ethics that ensures confidentiality, integrity and objectivity.

4.3. Anonymity

4.3.1. Reports can be submitted anonymously. However, providing contact details allows us to follow up and keep you informed about the investigation.

5. Protections for Whistleblowers

5.1. No Retaliation: Retaliation against whistleblowers is strictly prohibited. This includes dismissal, demotion, harassment, or any other form of adverse treatment.

5.2. Support: Whistleblowers will be provided with access to support services, such as counselling or legal advice, if needed.

5.3. Good Faith Reports: Whistleblowers acting in good faith will be protected, even if the reported concerns are found to be unsubstantiated. However, deliberately false or malicious reports may result in disciplinary action.

6. Investigation Process

6.1. Upon receiving a report, we will acknowledge receipt as soon as possible.

6.2. Reports will be assessed to determine if an investigation is warranted. If appropriate, an investigation will be initiated promptly.

6.3. Investigations will be conducted impartially and confidentially by the CCO or CTO, unless requested otherwise.

6.4. Whistleblowers may be asked to provide further information but are not obligated to participate.

6.5. The whistleblower will be informed of the progress and outcome of the investigation, subject to legal and confidentiality constraints.

7. Legal Compliance

7.1. This policy complies with relevant whistleblowing laws and regulations, including the Public Interest Disclosure Act 1998 (PIDA) in the UK and other applicable legal frameworks.