Whistleblowing policy

Our commitment

At Native Teams, we want everyone who works with us to feel confident that they can raise a concern about wrongdoing, knowing that it will be taken seriously and that they will be protected. Speaking up helps us to identify problems early, to put things right, and to protect our people, our clients, the individuals who use our Platform and our business.

This Policy explains what kinds of concerns can be reported, how to report them, how reports are handled, and the protections available to anyone who speaks up in good faith. It supports the commitments in our Code of Conduct, which encourages everyone to raise concerns early.

Who this Policy applies to

This Policy applies to Native Teams Limited and the companies in the Native Teams group. Anyone who has information about possible wrongdoing connected with Native Teams can use the reporting channels described in this Policy, including:

• our directors, employees, interns and volunteers, whether current or former;
• job applicants and people taking part in our recruitment processes;
• people who are employed, engaged or paid through our services;
• contractors, consultants and agency workers who work with us; and
• clients, suppliers, business partners and their employees.

What to report

What kinds of concerns should I report?

You can report any genuine concern about wrongdoing connected with Native Teams that you believe is in the public interest. You do not need to have proof, but you should have a reasonable belief that the information you are reporting is true and indicates wrongdoing.

Are there concerns that this Policy does not cover?

This Policy is not intended for personal grievances that relate only to your own situation, such as a disagreement about your own pay, performance review or working arrangements, unless the matter also raises a wider concern of wrongdoing. Personal grievances should be raised through the grievance process that applies to you, or with the business you work for. If you are not sure which route to use, you can still use the channels in this Policy, and we will make sure your concern is directed to the right place.

How to report a concern

You can raise a concern in the way that feels most comfortable to you. You can speak to your manager or another manager you trust, or you can contact our Legal & Compliance team directly by email at legal@nteams.com, marking your message as confidential.

If your concern involves a member of the Legal & Compliance team or senior management, you can raise it directly with a member of the board, and it will be handled independently of the people concerned.

What if I am not sure whether to report?

If you are unsure whether something should be reported, we would rather you raised it. You can contact the Legal & Compliance team for a confidential conversation before deciding whether to make a report. You should not investigate the matter yourself or try to gather evidence in a way that could break the law or put you at risk.

Confidentiality and anonymity

Will my identity be kept confidential?

Yes. We treat every report confidentially. Your identity, and any information that could identify you, will be shared only with the people who need to know it in order to handle your report, unless you agree otherwise or we are required to disclose it by law. Everyone involved in handling a report is bound by strict confidentiality obligations.

Can I report anonymously?

Yes. You can report a concern anonymously through our confidential online reporting channel. Anonymous reports are taken just as seriously as other reports. Please bear in mind that it can be harder to investigate a concern fully, and to give you feedback, if we are unable to contact you, so we encourage you to use a channel that allows us to communicate with you while keeping your identity protected.

Protection from retaliation

Will I be protected if I speak up?

Yes. Native Teams does not tolerate retaliation of any kind against anyone who raises a concern in good faith, even if the concern turns out to be mistaken. Retaliation is a serious breach of this Policy and our Code of Conduct, and anyone found to have retaliated against a person who has spoken up will face disciplinary or other appropriate action.

The same protection applies to anyone who helps a person to raise a concern, or who takes part in an investigation.

What happens after you report

How will my report be handled?

When we receive a report, we will acknowledge it within seven days, wherever we have a way to contact you. A designated, impartial member of our Legal & Compliance team, or another appropriate person who is independent of the matter, will then assess the report and decide how it should be handled. Depending on the nature of the concern, this may involve an internal investigation, an investigation by external specialists, or a referral to the relevant authorities.

Investigations are carried out fairly, objectively and as quickly as the circumstances allow. Anyone who is the subject of a report will be treated fairly, will be presumed innocent until the facts have been established, and will have the opportunity to respond.

Will I be told the outcome?

We will keep you informed of the progress of your report and give you feedback within three months of the acknowledgement, wherever we are able to contact you. The feedback will explain the action that has been taken or is planned. In some cases, we may not be able to share full details of an investigation or its outcome, for example to protect the confidentiality or legal rights of other people, but we will always tell you as much as we can.

What if I am not satisfied with how my report was handled?

If you are not satisfied with how your concern has been handled, you can raise the matter with a member of the board, who will review it independently.

Reporting to external authorities

Can I report a concern outside Native Teams?

We hope that you will feel able to raise concerns with us first, so that we have the opportunity to address them. However, you also have the right to report concerns directly to an appropriate external authority. In the United Kingdom, this includes the regulators and other bodies designated as prescribed persons under whistleblowing law, such as the Information Commissioner's Office for data protection matters. In the European Union, each country has designated competent authorities that can receive reports. Nothing in this Policy, or in any agreement with Native Teams, prevents you from reporting to a competent authority or limits your legal rights.

Reports made in bad faith

We ask that reports are made honestly and in good faith. Making a report that you know to be false, or making a report maliciously, is a serious matter and may lead to disciplinary or other appropriate action. This does not apply to a person who raises a genuine concern that turns out to be mistaken, who will always be protected.

Legal framework

This Policy reflects the whistleblowing laws that apply to Native Teams, including the UK Public Interest Disclosure Act 1998 and, for companies in the Native Teams group that are subject to them, the national laws implementing the EU Whistleblower Protection Directive. Where the law of a country where we operate gives greater protection than this Policy, that law applies.

Personal information and records

Personal information included in a report, or collected during an investigation, is processed only for the purposes of handling the report and in accordance with applicable data protection laws and our Privacy Policy. Information that is not relevant to the report is deleted. We keep records of reports and investigations securely, with access limited to the people who need it, and only for as long as necessary.

Questions

If you have any questions about this Policy or how to raise a concern, please contact the Legal & Compliance team at legal@nteams.com.