Whistleblower Policy

Purpose

Bugni Labs is committed to conducting business with honesty and integrity. This policy provides a mechanism for employees, contractors, and third parties to report suspected wrongdoing or concerns without fear of retaliation.

Scope

This policy covers reporting of:

  • Criminal offences or breach of legal obligations
  • Fraud, bribery, or corruption
  • Financial irregularities or misappropriation
  • Breaches of professional or ethical standards
  • Data protection violations
  • Health and safety dangers
  • Environmental damage
  • Modern slavery or human trafficking
  • Attempts to conceal any of the above

Who Can Report

This policy is available to all employees, contractors, consultants, suppliers, and any third parties who have concerns about our operations or conduct.

How to Report

Concerns can be reported:

  • Email: whistleblower@bugni.io (monitored by designated independent officers)
  • In person: To any director or designated compliance officer
  • In writing: Sealed envelope marked "Confidential"

Reports can be made anonymously, though providing contact information helps with investigation and follow-up.

What to Include

When reporting, provide:

  • Nature of the concern
  • Background and history
  • Names, dates, and locations if known
  • Evidence or supporting information
  • Whether the matter has been reported elsewhere

Protection from Retaliation

We prohibit retaliation against anyone who reports concerns in good faith. Retaliation includes dismissal, discipline, threats, harassment, discrimination, or any detrimental treatment.

Anyone who retaliates against a whistleblower will face disciplinary action, up to and including termination.

Confidentiality

We treat reports confidentially to the extent possible. The reporter's identity will not be disclosed without consent, except where required by law or necessary for investigation.

Investigation Process

Upon receiving a report:

  • Acknowledgment of receipt (if contact provided)
  • Assessment of the concern and scope
  • Investigation by appropriate personnel (may involve external investigators)
  • Findings and recommendations
  • Action taken (corrective measures, disciplinary action, policy changes)
  • Feedback to reporter where feasible

Timeframes

We aim to acknowledge reports within 5 working days and complete investigations within a reasonable timeframe, typically 30-60 days depending on complexity. Complex matters may take longer.

False or Malicious Reports

Protection is provided for reports made in good faith. Deliberately false or malicious reports may result in disciplinary action.

External Reporting

While we encourage internal reporting first, you may also report to external bodies:

  • Information Commissioner's Office (ICO) for data protection concerns
  • Financial Conduct Authority (FCA) for financial services matters
  • Health and Safety Executive (HSE) for safety concerns
  • Police for criminal matters
  • Other relevant regulators or prescribed persons

Contact

Whistleblower hotline: whistleblower@bugni.io

General compliance: compliance@bugni.io