Whistleblowing Policy

A guide to reporting wrongdoing

Revision 05
Reviewed 14 Mar 2025

Signed by the designated controller:
Alexander Bright

1.1 YOUR AUDIENCE LTD ("the Company") is committed to maintaining a culture of integrity, transparency, and accountability. This policy applies to all stakeholders, including employees, customers, suppliers, business partners, and the local community. We actively encourage anyone connected to the Company to report any concerns regarding misconduct, unethical behaviour, or illegal activities.

1.2 The Company is committed to ensuring that whistleblowers are protected from retaliation. Any individual making a good faith disclosure will not be subject to any form of retaliation, discrimination, or adverse treatment as a result of their disclosure.

1.3 The law allows individuals to make a ‘protected disclosure’ of certain information. In order to be ‘protected’, a disclosure must relate to a specific subject matter (Section 2) and the disclosure must also be made in an appropriate way (Section 3). Whistleblowing protection is confined to a disclosure which, in the reasonable belief of the individual making the disclosure, is made in the public interest.

2.1 An individual should report any concern that they reasonably believe tends to show one or more of the following:

• A criminal offence has been, is being, or is likely to be committed.

• A person has failed, is failing, or is likely to fail to comply with a legal obligation.

• A miscarriage of justice has occurred, is occurring, or is likely to occur.

• The health or safety of any individual has been, is being, or is likely to be endangered.

• Environmental damage has been, is being, or is likely to occur.

• Information related to any of the above is being, or is likely to be, deliberately concealed.

• Bribery or corruption, including the offering or receiving of bribes or facilitation payments.

• Financial fraud, misrepresentation, or improper accounting practices.

• Unethical business practices, including conflicts of interest.

• Non-compliance with company policies or legal regulations.

• Discrimination, harassment, bullying, or any form of workplace misconduct.

• Safety violations that could endanger employees, customers, or the public.

2.2 Concerns should be reported through the Company’s disclosure procedure outlined below.

3.1 Individuals who have concerns should raise them promptly using the following channels:

1. Direct Line Manager – If appropriate, employees should first disclose their concerns to their line manager.
2. Alternative Internal Contact – If it is inappropriate to report to the line manager, employees may contact the directors via the dedicated whistleblowing email: speakout@audience.co.uk.
3. Ethics Hotline – A confidential ethics hotline is available for anonymous reporting. Contact details can be found on the company intranet.
4. External Reporting – If concerns are not addressed internally, or if the whistleblower believes the issue cannot be raised internally, they may seek advice from Protect Advice at 020 7404 6609, which offers confidential guidance. Additionally, concerns may be reported to regulatory bodies or law enforcement when necessary.

3.2 The Company encourages internal reporting to facilitate prompt investigation and resolution. However, it recognises that there may be instances where external disclosure is necessary.

4.1 The Company will follow a structured approach to investigating concerns:

• Promptly acknowledging receipt of a report.

• Assigning a designated investigator who has no direct reporting relationship to the accused party.

• Conducting thorough investigations, including interviews with relevant parties.

• Documenting findings and taking appropriate corrective action.

• Keeping the whistleblower informed of the status of their report, where possible and appropriate.

4.2 If a whistleblower believes the investigation process has been mishandled, they may raise concerns through the designated reporting channels.

5.1 The Company is committed to protecting whistleblowers from any form of retaliation, including but not limited to:

• Dismissal, demotion, or suspension.
• Unjustified negative performance reviews or disciplinary actions.
• Harassment, bullying, or discrimination.
• Any other form of adverse treatment as a result of raising a concern.

5.2 Any act of retaliation against a whistleblower will be treated as a serious disciplinary matter and may result in disciplinary action, including termination of employment or other contractual relationships.

5.3 Employees or stakeholders who believe they have been subjected to retaliation should report it through the designated whistleblowing channels. Reports of retaliation will be investigated and appropriate action will be taken.

6.1 To ensure the protection of whistleblowers, the Company will implement the following confidentiality measures:

• Whistleblowers may choose to remain anonymous when making a report.

• The identity of the whistleblower will be kept strictly confidential unless disclosure is required by law.

• Information related to whistleblowing reports will be shared only with individuals necessary to conduct a fair and thorough investigation.

• Any breach of confidentiality will be treated as a disciplinary offence.

7.1 If retaliation against a whistleblower is identified, the following consequences will apply:

• Disciplinary Action – Employees found guilty of retaliating against whistleblowers will face disciplinary measures, up to and including termination of employment.
• Contractual Penalties – Third-party contractors or business partners engaging in retaliation may have their contracts reviewed or terminated.
• Legal Consequences – The Company reserves the right to take legal action against any individual or entity found guilty of retaliating against a whistleblower.

8.1 The Company will ensure whistleblowers receive follow-up communication where possible, including:

• Confirmation of report receipt.
• Updates on the status of the investigation.
• General information on actions taken, where appropriate.

8.2 If a whistleblower is dissatisfied with how their report has been handled, they may raise their concerns through alternative reporting channels, see point 3.1 external reporting, for more details.