Report Misconduct

1. Purpose
SmartStruct is committed to the highest standards of integrity, transparency, and accountability. This policy encourages employees, contractors, and stakeholders to report concerns about suspected misconduct, wrongdoing, or unethical behaviour, without fear of retaliation.

2. Scope
This policy applies to all employees, contractors, consultants, and third parties who may have concerns about:

• Fraud, theft, or financial irregularities
• Unlawful or unethical behaviour
• Health and safety risks
• Harassment, bullying, or discrimination
• Environmental breaches
• Any other serious wrongdoing

3. Principles

• Confidentiality: All reports will be treated confidentially to protect the identity of the whistleblower.
• Anonymity: Reports can be made anonymously through [link to your reporting platform].
• No Retaliation: Retaliation against anyone raising concerns in good faith is strictly prohibited.
• Prompt Investigation: All concerns will be reviewed and, where necessary, investigated promptly and fairly.
• Transparency: Whistleblowers may receive updates on the progress of investigations via a secure and confidential method.

4. How to Report a Concern
Online: Submit a report via our anonymous whistleblowing form. Include as much detail as possible—dates, locations, people involved, and supporting evidence—to help with the investigation.

5. Investigation Process

• Receipt: Reports will be acknowledged promptly.
• Assessment: The concern will be assessed for credibility and urgency.
• Investigation: A fair and confidential investigation will be conducted by a Compliance Officer or designated team.
• Outcome: Appropriate action will be taken based on the findings, and the whistleblower will be informed, if they wish and have chosen to provide their contact details.

6. Responsibilities

• Whistleblower: Provide honest, factual information.
• Managers/Investigators: Treat reports seriously, maintain confidentiality, and act without bias.
• Senior Management: Ensure protection of whistleblowers and implement corrective actions where needed.

7. Data Protection
All personal data collected through whistleblowing reports will be handled in accordance with GDPR. No personal contact information will be stored, and whistleblowers will not be contacted unless they have chosen to provide such information and have therefore chosen to be contacted.

Whistleblower information may be used during the investigation and reporting process, and law, regulatory authorities, or judicial proceedings may require disclosure.

8. Policy Review
This policy will be reviewed annually or when required by changes in legislation, best practices, or organisational structure.