Whistleblowing Policy April 2021

1. About this Policy

We are committed to conducting our business with honesty and integrity and we expect all working for Zzoomm to maintain high standards. Any suspected wrongdoing should be reported as soon as possible.

This policy covers all employees, subcontractors, consultants, contractors, casual workers and agency workers.

This policy does not form part of any employee’s contract of employment and we may amend it at any time.

2. What is Whistleblowing?

Whistleblowing is the reporting of suspected wrongdoing or dangers in relation to our activities. This includes bribery, facilitation of tax evasion, fraud or other criminal activity, miscarriages of justice, health and safety risks, damage to the environment and any breach of legal or professional obligations.

If your complaint is about the way people are behaving towards you please refer to our policy on Anti-Harassment and Bullying or to the Grievance Procedure on how to proceed rather than use this policy.

3. How to raise a Concern

In most cases you will be able to raise any concerns with your manager. However, where you prefer not to raise it with your manager for any reason, you should contact the People Director or the Chief Executive. If you have a concern regarding an employee on the Senior Leadership Team, you should contact Massimo Prelz-Oltramonti. Contact details are at the end of this policy.

We will arrange a meeting with you as soon as possible to discuss your concern. You may bring a colleague or a trade union representative to any meetings under this policy. Your companion must respect the confidentiality of your disclosure and any subsequent investigation.

4. Confidentiality

We hope that you will feel able to voice whistleblowing concerns openly under this policy. Completely anonymous disclosures are difficult to investigate. If you want to raise your concern confidentially, we will make every effort to keep your identity secret and only reveal it where necessary to those involved in investigating your concern.

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5. External Disclosures

The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In most cases you should not find it necessary to alert anyone externally.

The law recognises that in some circumstances it may be appropriate for you to report your concerns to an external body such as a regulator. We strongly encourage you to seek advice before reporting a concern to anyone external. Protect, an Independent Whistleblowing Charity operates a confidential helpline. Their contact details are at the end of this policy.

6. Protection and Support for Whistleblowers
We aim to encourage openness and will support whistleblowers who raise genuine concerns under

this policy, even if they turn out to be mistaken.

Whistleblowers must not suffer any detrimental treatment as a result of raising a genuine concern. If you believe that you have suffered any such treatment, you should inform the People Director immediately. If the matter is not remedied, you should raise it formally using our Grievance Procedure.

You must not threaten or retaliate against whistleblowers in any way. If you are involved in such conduct you may be subject to disciplinary action. However, if we conclude that a whistleblower has made false allegations maliciously, the whistleblower may be subject to disciplinary action.

Protect operates a confidential helpline. Their contact details are at the end of this policy.

7. Contacts