Whistleblowing Policy

CCUK WHISTLEBLOWING POLICY

Our Whistleblowing policy is designed to promote a culture of openness, integrity and accountability within CCUK. It provides a safe and confidential process for employees, contractors and other stakeholders to raise concerns about suspected wrongdoing, malpractice, or unethical behaviour.

INTRODUCTION

The Executive Team are committed to conducting our business with honesty and integrity and we expect all employees to maintain high standards. We are committed to ensuring that individuals who speak up in good faith are supported and protected from retaliation.

Providing you are raising a genuine concern, it does not matter if you are mistaken. We do not extend this assurance to someone who maliciously raises a matter they know is untrue.

If you raise a genuine concern under this policy, you will not be at risk of losing your job or suffering any form of reprisal as a result. We will not tolerate the harassment or victimisation of anyone raising a genuine concern and we consider it a disciplinary matter to victimise anyone who has raised a genuine concern.

With these assurances, we hope you will raise your concern openly.

Concerns would typically include:

• Criminal offences (fraud, bribery, theft, money laundering)

• Health and safety risks (unsafe working conditions, improper handling of hazardous materials)

• Breaches of legal or regulatory obligations (environmental damage, data protection violations, failure to meet statutory requirements)

• Miscarriages of justice

• Corruption or financial malpractice (misuse of funds, corporate tax evasion)

• Serious ethical concerns or improper behaviour

This policy outlines how concerns can be reported, how they will be handled, and the protections available to those who come forward. It aims to encourage early disclosure and ensure that all disclosures are taken seriously and investigated appropriately.

If you are unsure about raising a concern, you can get independent advice from Protect, the UK’s whistleblowing charity.

WHO IS THIS POLICY FOR?

This policy applies to all those who work with us or for us; whether full-time or part- time, or on a consultancy basis. If your concern relates solely to your own treatment at work (for example, bullying, lack of training or an issue with your pay), then use the Grievance Policy, available in Hero. If you have a concern about financial misconduct or fraud, also see our Anti-Fraud Policy. If you have a concern about safeguarding, also see our Safeguarding Policy.

HOW TO RAISE A CONCERN INTERNALLY

Remember that you do not need to provide detailed evidence when raising a concern. However, we do ask that you explain as fully as you can the information or circumstances that gave rise to your concern.

STEPS TO FOLLOW

• Raise a concern with your Manager. This may be done orally or in writing.
• If you feel unable to raise the matter with your Manager, for whatever reason, raise the matter with a member of the Executive Team — Gavin Bruce, Grace Orr, Lee Whitehouse, or Kevin Tierney. They have been given specialist responsibility and training in dealing with whistleblowing concerns.
• If this process has been followed and your concerns are unresolved, or if you feel that the matter is so serious that you can’t discuss it with any of these individuals, please contact Mark Lee, Chief Executive Officer.

HOW WE WILL HANDLE THE MATTER

• We will acknowledge receipt of your concern within two working days.
• We will assess it and consider what action may be appropriate. This may involve an informal review, an internal inquiry, or a more formal investigation.
• We will tell you who will be handling the matter, how you can contact them, and what further assistance we may need from you.
• If you ask, we will write to you summarising your concern and setting out how we propose to handle it, and provide a timetable for updates and/or feedback.
• If we have misunderstood the concern or there is any information missing, let us know.
• If you have any personal interest in the matter, we do ask that you tell us at the outset. If we think your concern falls more appropriately within our grievance, bullying and harassment, or other relevant procedure, we will let you know and explain why.
• Whenever possible, we will give you feedback on the outcome of any investigation. Note, however, that we may not be able to tell you the precise actions we have taken where this would infringe a duty of confidence we owe to another person.
• While we cannot guarantee that we will respond to all matters in the way that you might wish, we will strive to handle the matter fairly and properly. By using this policy, you will help us to achieve this.

VICTIMISATION

We are grateful to employees who come forward with information, and we will not tolerate any attempt to silence or victimise people for speaking up. Any instances of whistleblower victimisation will be treated as a disciplinary matter. Examples of victimisation could include bullying, disciplinary action as a result of whistleblowing or any attempt to identify a whistleblower. If you experience reprisal, harassment or victimisation after raising a concern, alert the person you raised your whistleblowing concern with. If the matter is not remedied, you should raise it formally using our grievance procedure. RAISING A MATTER EXTERNALLY While we hope this policy gives you the reassurance you need to raise your concern internally with us, we recognise that there may be circumstances where you can only properly report a concern by raising it with an outside body. The external reporting bodies relating to our business are • The Financial Conduct Authority • The Health and Safety Executive • The Information Commissioner’s Office • Ofcom

DATA PROTECTION

We will keep a confidential record of your concern. This will be held in accordance with our Privacy Policy, Data Protection Policy and relevant data protection legislation.