Whistleblowing Policy

1. Introduction and Purpose

Wazoku Limited (“Wazoku”, “we”, “our”, or “the Company”) is committed to maintaining the highest standards of ethical conduct, corporate governance, and transparency in all our operations. As an innovation management platform that enables organisations to solve challenges and drive positive change, we recognise our responsibility to ensure that our work—and the work we facilitate for our clients—aligns with these principles.

This Whistleblowing Policy establishes a framework for employees, contractors, and other stakeholders to raise concerns about suspected wrongdoing, malpractice, or risks without fear of retaliation. We encourage a culture of openness where individuals feel safe to speak up when they observe conduct that may be unlawful, unethical, or harmful.

This policy is designed to complement, not replace, existing grievance procedures, health and safety protocols, and other internal reporting mechanisms.

1.1 Definitions

Whistleblower: Any individual who, in good faith, reports a concern about suspected wrongdoing, malpractice, or risk in connection with Wazoku’s activities, whether internally or to an external authority. This includes employees, contractors, suppliers, and any other person covered by Section 2.1 of this policy. A whistleblower may also be referred to as a “reporter” or “disclosing party” throughout this policy.

Retaliation: Any direct or indirect adverse action, treatment, or consequence taken against a whistleblower, or a person associated with a whistleblower, because they have raised a concern, participated in an investigation, or supported a reporter under this policy. Retaliation may be overt (e.g., dismissal, demotion) or subtle (e.g., social exclusion, changes to workload or duties, covert monitoring). It includes acts by managers, colleagues, clients, contractors, or other third parties connected to Wazoku. Examples of prohibited retaliation are set out in Section 6.2.

2. Scope

2.1 Who This Policy Applies To

This policy applies to all individuals working at or with Wazoku, including:

• Employees (permanent, fixed-term, and part-time)
• Directors and officers
• Contractors, consultants, and agency workers
• Interns and work experience participants
• Suppliers and their employees
• Any other person who becomes aware of wrongdoing in connection with Wazoku’s activities

2.2 Geographic Scope

This policy applies globally to all Wazoku operations and business activities, regardless of location.

3. What Can Be Reported

3.1 Qualifying Disclosures

A qualifying disclosure is one made in good faith where the individual reasonably believes that one or more of the following is occurring, has occurred, or is likely to occur:

• Criminal offences, including fraud, bribery, and corruption
• Failure to comply with legal obligations
• Miscarriages of justice
• Danger to health and safety
• Damage to the environment
• Financial malpractice or impropriety
• Breach of data protection or privacy regulations
• Breach of company policies or codes of conduct
• Deliberate concealment of any of the above
• Concerns about customer projects with potential adverse social or environmental impact (see Section 3.2)

3.2 Customer Projects with Potential Adverse Social or Environmental Impact

As an innovation management platform, Wazoku facilitates challenges and projects for a diverse range of clients across multiple sectors. We acknowledge that some projects, while legally compliant, may raise ethical concerns regarding their potential social or environmental impact. Employees and stakeholders are explicitly encouraged to raise concerns in this area.

Reportable concerns include, but are not limited to:

Environmental Impact Concerns:

• Projects that may contribute significantly to carbon emissions, deforestation, or biodiversity loss
• Challenges designed to extend the life of environmentally harmful technologies or practices
• Innovation projects for clients with poor environmental track records where the project could enable further harm
• Projects that may facilitate pollution, toxic waste, or environmental degradation
• Concerns about greenwashing—projects presented as environmentally beneficial but lacking substance

Social Impact Concerns:

• Projects that may enable human rights violations, including in supply chains
• Challenges for clients in sectors associated with human exploitation or forced labour
• Innovation that could lead to significant job displacement without consideration for affected communities
• Projects for clients operating in conflict zones or under international sanctions
• Work that could facilitate surveillance, censorship, or suppression of civil liberties
• Projects that may enable discrimination or exacerbate social inequality
• Concerns about projects for defence, weapons, or dual-use technology applications

Governance and Ethics Concerns:

• Clients with documented records of corruption, bribery, or unethical business practices
• Projects that may conflict with Wazoku’s stated values or public commitments
• Concerns about the end use of innovations developed through our platform
• Projects where there is a significant gap between client claims and reality

Important: Raising a concern under this section does not require certainty that harm will occur. A reasonable, good-faith belief that a project warrants ethical review is sufficient grounds for a report. The Company will assess all such concerns through our Ethics Review process (see Section 7.3).

3.3 What This Policy Does Not Cover

This policy is not intended for:

• Personal grievances relating to employment terms, performance management, or interpersonal disputes (use the Grievance Procedure)
• Complaints about harassment or bullying (use the Anti-Harassment Policy)
• Routine customer service complaints

4. How to Raise a Concern

4.1 Internal Reporting Channels

Concerns may be raised through any of the following channels:

Channel	Contact Details
Line Manager	Your direct line manager (unless the concern relates to them)
People Team	Lucy.jenner@wazoku.com
Designated Whistleblowing Officer	whistleblowing@wazoku.com
Chief Marketing Officer	Ian.smyth@wazoku.com
Board Chair	john@yeomans.org.uk (for concerns about senior leadership)

4.2 Confidential Reporting

All reports will be treated confidentially. Where possible, we will protect the identity of the reporter, sharing information only with those who need to know for the purpose of investigating and addressing the concern.

4.3 Anonymous Reporting

While we encourage reporters to identify themselves (which helps us investigate more effectively and provide feedback), we accept anonymous reports. Anonymous reports may be submitted in writing to the Designated Whistleblowing Officer. Please note that anonymous reports may be more difficult to investigate and we will be unable to provide updates on progress.

4.4 Information to Include

When raising a concern, please provide as much detail as possible, including:

• The nature of the concern
• Names of individuals involved (if known)
• Dates, times, and locations
• Any documentary evidence
• Whether the concern has been raised previously
• For customer project concerns: the client name, project details, and specific nature of the potential adverse impact

5. Confidentiality

Wazoku will make every effort to protect the confidentiality of individuals who raise concerns. Information will be disclosed only to those with a legitimate need to know in order to investigate and address the concern. If disclosure becomes necessary (for example, as part of legal proceedings), we will discuss this with the reporter in advance where possible.

Reporters should also maintain appropriate confidentiality regarding their concern and the investigation process to protect the integrity of the investigation and the rights of those involved.

6. Protection from Retaliation

6.1 Our Commitment

Wazoku will not tolerate any form of retaliation, harassment, victimisation, or detrimental treatment against anyone who raises a genuine concern in good faith, even if the concern is not ultimately substantiated. This protection extends to anyone who participates in an investigation or supports a reporter.

6.2 Examples of Prohibited Retaliation

Prohibited retaliation includes, but is not limited to:

• Dismissal or termination of contract
• Demotion, denial of promotion, or adverse performance reviews
• Reduction in pay or benefits
• Exclusion, isolation, or changes to work duties
• Bullying, harassment, or intimidation
• Disciplinary action
• Any other action that would discourage a reasonable person from raising a concern

6.3 Reporting Retaliation

Anyone who believes they have been subjected to retaliation for raising a concern should report this immediately to the Designated Whistleblowing Officer or the Board Chair. Allegations of retaliation will be investigated promptly and, if substantiated, will result in disciplinary action up to and including dismissal.

6.4 Mechanisms for Whistleblower Protection

Wazoku will implement the following active protection mechanisms to safeguard whistleblowers from the moment a concern is received:

(a) Risk Assessment: Upon receipt of a report, the Designated Whistleblowing Officer will conduct an immediate risk assessment to identify whether the whistleblower may be at risk of retaliation. The assessment will consider the nature of the concern, the parties implicated, the whistleblower’s role and relationship to those parties, and any prior indications of hostility or pressure.

(b) Interim Protective Measures: Where the risk assessment identifies a significant risk of retaliation, Wazoku will implement interim measures proportionate to that risk. These may include: restricting access to the whistleblower’s identity on a need-to-know basis; adjusting reporting lines or work arrangements to reduce contact with implicated parties; enhanced monitoring of the whistleblower’s working conditions; or, where appropriate, temporary reassignment of the implicated individual pending investigation.

(c) Confidentiality Enforcement: All individuals involved in handling a whistleblowing report — including investigators, HR personnel, and senior managers — will be required to sign a confidentiality undertaking. Any breach of confidentiality will itself be treated as a serious disciplinary matter.

(d) Named Support Contact: Every whistleblower will be assigned a named support contact (distinct from the investigator) who will serve as a point of contact throughout the process, provide updates, and promptly flag any concerns about potential retaliation to the Designated Whistleblowing Officer.

(e) Third-Party Involvement: Where a concern involves the most senior members of the organisation, or where internal objectivity cannot be assured, Wazoku may engage an independent external specialist (such as a qualified employment lawyer, an independent HR consultant, or an external ethics body) to oversee or conduct the investigation and/or the retaliation review. Whistleblowers who feel the internal process is compromised may also report directly to prescribed external bodies (see Section 9).

6.5 Process Steps in the Event of Retaliation

If a whistleblower believes they have experienced or are at risk of retaliation, the following steps apply:

Step 1 — Immediate Report: The whistleblower (or their support contact on their behalf) reports the suspected retaliation to the Designated Whistleblowing Officer at whistleblowing@wazoku.com, or to the Board Chair at john@yeomans.org.uk where the Whistleblowing Officer may be implicated. The report may be made verbally or in writing and should be made as soon as practicable.

Step 2 — Acknowledgement and Triage (within 2 working days): The Designated Whistleblowing Officer acknowledges receipt of the retaliation report and determines urgency. Where there is an immediate risk to the whistleblower’s employment, wellbeing, or physical safety, interim protective measures (see Section 6.4(b)) will be activated without delay.

Step 3 — Separate Investigation: A retaliation investigation will be conducted separately from and in parallel with any ongoing investigation into the underlying concern. The investigator must be independent of the parties implicated in the alleged retaliation. Where appropriate, an external third party will be appointed (see Section 6.4(e)).

Step 4 — Outcome and Consequences: If retaliation is substantiated, Wazoku will take disciplinary action against the individual(s) responsible, up to and including summary dismissal for gross misconduct. Where the retaliatory act constitutes a criminal offence (e.g., harassment, unlawful detriment), Wazoku will refer the matter to the relevant external authority. The whistleblower will be informed of the outcome and the action taken, subject to confidentiality obligations relating to other individuals.

Step 5 — Remediation and Restoration: Where a whistleblower has suffered a detriment as a result of substantiated retaliation (for example, loss of earnings, demotion, or damage to professional reputation), Wazoku will take reasonable steps to remediate that detriment, including reinstatement to a former role, pay restoration, or other appropriate remedy. A written record of actions taken will be maintained.

Step 6 — External Escalation: At any stage, a whistleblower retains the right to seek independent legal advice or to report alleged retaliation to an external prescribed body (see Section 9) or an employment tribunal. Wazoku will not obstruct or penalise any individual for exercising these rights.

6.6 Bad Faith Reports

While we encourage all genuine concerns to be raised, the protections under this policy do not extend to individuals who make allegations they know to be false or who raise concerns maliciously. Such conduct may result in disciplinary action.

7. Investigation Process

7.1 Acknowledgement

All concerns will be acknowledged within five (5) working days of receipt. The acknowledgement will confirm who is handling the concern and outline the expected process.

7.2 Initial Assessment

An initial assessment will determine whether the concern falls within the scope of this policy and what further action is required. This may include deciding whether to conduct a formal investigation, refer to another process, or take immediate action.

7.3 Investigation

Where a formal investigation is warranted, it will be conducted by an appropriate person who is independent of the matter and has no conflict of interest. The investigation will be:

• Thorough and objective
• Conducted as quickly as is reasonable given the complexity of the matter
• Fair to all parties involved
• Documented appropriately

7.4 Ethics Review Process for Customer Project Concerns

Concerns raised under Section 3.2 (Customer Projects with Potential Adverse Social or Environmental Impact) will be subject to a dedicated Ethics Review process, which includes the following steps:

1. Initial Triage (within 5 working days): The Designated Whistleblowing Officer will assess whether the concern requires immediate escalation or can proceed through standard review.
2. Ethics Committee Review: Significant concerns will be referred to the Ethics Committee, comprising senior representatives from Operations, Legal, and an independent non-executive director (where applicable).
3. Assessment Criteria: The Committee will assess the project against Wazoku’s values, applicable regulations, industry standards, and the potential for harm.
4. Outcomes: Possible outcomes include continuation of the project with enhanced safeguards, modification of project scope, client engagement to address concerns, or termination of the engagement.

7.5 Feedback to Reporters

Subject to legal constraints and the need to protect confidentiality, we will keep reporters informed of progress and, where possible, the outcome of any investigation. We aim to provide updates at least every four weeks during an active investigation.

8. Outcomes

Where wrongdoing is substantiated, Wazoku will take appropriate action, which may include:

• Disciplinary action against individuals (up to and including dismissal)
• Referral to external authorities (e.g., police, regulators)
• Changes to policies, procedures, or controls
• Termination of client or supplier relationships
• Modification or cessation of projects
• Other remedial measures as appropriate

9. External Reporting

We encourage individuals to use our internal reporting channels in the first instance. However, we recognise that in some circumstances, individuals may feel it necessary to report externally. In the UK, the Public Interest Disclosure Act 1998 (as amended) provides legal protection for individuals who make qualifying disclosures to prescribed persons or bodies.

Relevant prescribed bodies may include:

• The Information Commissioner’s Office (ICO) for data protection concerns
• The Financial Conduct Authority (FCA) for financial misconduct
• The Environment Agency for environmental concerns
• The Health and Safety Executive (HSE) for health and safety concerns
• The Serious Fraud Office (SFO) for serious fraud or corruption

10. Record Keeping

Records of all concerns raised under this policy will be maintained securely and in accordance with data protection legislation. Records will include the nature of the concern, how it was investigated, and the outcome. These records will be retained for a minimum of seven years following the conclusion of the matter.

11. Training and Awareness

All employees will receive training on this policy as part of their induction and through periodic refresher training. Managers will receive additional training on how to receive and handle concerns appropriately.

12. Policy Review

This policy will be reviewed annually or sooner if required by changes in legislation, best practice, or organisational needs. The Board will be informed of any significant concerns raised under this policy and the outcomes of investigations through regular reporting.

In the interests of transparency and to fulfil Wazoku’s commitment to stakeholder trust, this policy will be made publicly available on the Wazoku website. When a concern is received, the Designated Whistleblowing Officer will ensure the reporter is provided with a copy of this policy (or directed to the relevant public-facing version) so that they are fully informed of their rights and the protections available to them. Following each annual review, any material changes to protections or procedures will be communicated to all employees and posted publicly.

13. Questions About This Policy

If you have any questions about this policy or how to raise a concern, please contact the Designated Whistleblowing Officer at whistleblowing@wazoku.com or speak to a member of the People Team.