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Whistleblowing Policy

1: Scope

This document establishes the Whistleblowing Policy for Svella Connect Limited and Svella Asset Services Limited. References in this policy to the “Company” are to Svella Asset Services Limited and Svella Connect Limited.

2: Purpose

The Company is committed to operating at all times, and in everything we do, to the highest standards of integrity.

The aim of this policy is to provide a mechanism to immediately report any concerns regarding conduct which is dangerous, against the law or breaches ethical or professional codes.

The Whistleblowing Policy for Svella Connect Limited and Svella Asset Services Limited will be brought to the attention of all our people, subcontractors, and members of the public. The Policy does not form part of an individual’s contract of employment or a subcontractor's terms of engagement and may be amended by the Company from time to time and will be reviewed annually.

3: General Data Protection Regulation

The Company processes personal data in connection with the subject matter of this policy in accordance with the requirements of the General Data Protection Regulation (GDPR). Any failure to comply with GDPR can have serious results including breach of the persons rights and ﬁnancial penalties for the Company.

4: Overview

The Company wants to ensure that our employees, subcontractors, and members of the public are encouraged and enabled to raise serious concerns within the Company rather than overlooking a problem or seeking assistance externally.

4.1: What does the policy apply to?

The whistleblowing policy applies to the disclosure of a concern, which, in the individual’s honest reasonable belief,

suggests that wrongdoing has been committed, is being committed, or is likely to be committed.

4.2: What types of activities are typically considered relevant to whistleblowing?

The following is not an exhaustive list, but the types of concerns employees, subcontractors or members of the public may want to raise with the Company by whistleblowing could include:

Any activity you suspect is criminal
Any ﬁnancial malpractice or impropriety of fraud
Any activity you suspect puts health and safety at risk

Any activity you suspect may damage the environment
Any activity you suspect breaches our policy on bribery and corruption
Any failure to comply with legal or regulatory obligations
Any failure to meet professional requirements
Any attempt to conceal one of more of these activities

If you are an employee and your complaint is about the behaviour of others towards you, the Company’s grievance policy contains guidance on how to proceed.

4.3: Confidentiality and anonymity

Employees, subcontractors, and members of the public are always encouraged to raise concerns openly, and we actively discourage anonymous whistleblowing. This is because it is not always easy to manage and investigate anonymous reports, especially since if we are unable to ask for clariﬁcation or further details, the Company may struggle to clarify and ﬁnd evidence to support the allegations and/or reach an informed conclusion.

However, if employees, subcontractors, or members of the public wish to keep their identities anonymous, the Company will do all it can to ensure that they are able to retain their anonymity, and the conﬁdentiality of their concerns, as far as possible. If the Company needs to disclose anyone's identity to others as part of the investigation, this will always be discussed with that individual beforehand.

The identity of the person raising concerns may be required to be revealed toothers in certain circumstances:

Where the Company has a legal obligation
Where the individual’s identity or the matters relating to the concern are already in the public domain
On a strictly conﬁdential basis to the Company’s professional advisors for the purposes of obtaining advice
To the police or other authorities as required under legislation

4.4: Raising the concern

We would hope that, in the ﬁrst instance, employees would feel able to raise a concern their line manager or a director.

If, this is an external concern or for whatever reason, if employees feel they cannot talk to their manager or director or feel that their concerns have not been addressed appropriately, then whistleblowing@svellaconnect.com should be contacted.

The matter will be investigated promptly by independent employees under the supervision of the CEO/HR Director/IT Director.

It is likely that the person undertaking the investigation will want to meet with or talk to the individual who has raised

the concern.

If the concern has been raised by an employee, at any stage, the individual raising the concern under the whistleblowing procedure may be accompanied to any meetings to discuss their concern by either a fellow employee of their choice or a trade union representative.

The period over which the investigation will take place will depend on the nature of the concern raised, but if appropriate, the HR Director/IT Director/CEO will advise the individual who has raised the concern of the progress of any investigation (usually within 3 months.)

4.5: Outcome of investigation

At the conclusion of any investigation, the person investigating the matter will, if appropriate and allowable by law:

Inform the individual raising the concern of the outcome of the investigation; and
Inform the individual(s) who were the subject of the concern; and

Inform the Company’s leadership team or other external authorities who may need to consider whether any action should be taken as a result of the investigation.

The investigator will register the concern and make a record of the outcome of the investigation.

4.6: Protection of whistleblowers

If employees have raised a concern in good faith, the Company’s process and all those giving eﬀect to it will support and protect employees. However, if a false concern is raised in bad faith (e.g., for malicious intent and reasons), this will invoke the Company’s disciplinary policy and employees may be subject to disciplinary action.