Whistleblowing (Speak Up) Policy
1) Overview
This Whistleblowing (Speak Up) Policy (“Policy”) explains how Caribou Digital (UK) Limited and its subsidiaries and affiliates (together, “Caribou”) enable anyone to raise concerns about wrongdoing safely and confidentially. It sets binding standards for our people and for third-parties who act for or with us. Where laws differ, the higher/stricter standard applies.
This Policy applies to employees, officers, board members, contractors, consultants, agents/intermediaries, suppliers, vendors, partners, grantees, research participants, and other stakeholders (collectively, “Associated Persons”).
2) Our commitment
- We encourage speaking up about suspected wrongdoing.
- We will protect good-faith reporters from retaliation.
- We will handle concerns promptly, fairly, and confidentially, sharing information strictly on a need-to-know basis.
- We will act on findings and learn from incidents.
3) What to report (examples)
Associated Persons should report any concern they reasonably believe involves wrongdoing, risk, or misconduct related to Caribou’s activities, including:
- Bribery or corruption, fraud, theft, embezzlement; Money-laundering or terrorist-financing concerns; kickbacks, or improper gifts/hospitality. (see our Anti-Bribery and Anti-Corruption Policy)
- Conflicts of interest (see our Conflict of Interest Policy)
- Breaches of law, contract, or Caribou policies
- Safeguarding concerns involving children or vulnerable adults (see our Safeguarding Policy)
- Modern slavery or human-rights abuses in our supply chain (see our Modern Slavery and Human Trafficking Statement)
- Health and safety risks.
- Social or environmental harm (see our Corporate Social Responsibility Policy)
- Retaliation against someone who raised a concern in good faith (covered in this policy).
Routine workplace issues (e.g., performance feedback, leave requests) should follow the HR/Grievance route. If anyone is in immediate danger, contact local emergency services first.
4) How to report
Choose whichever route feels safest for you. You can report confidentially and, where permitted by law, anonymously.
- EthicsPoint (confidential; available 24/7): cariboudigital.ethicspoint.com
- Internal contacts: your line manager or Point of Contact at Caribou.
- The CEO or the Board Chair.
Please share what happened, when/where, who was involved, any evidence, and any witnesses.
5) What happens next
- Acknowledgement: we aim to acknowledge EthicsPoint reports within 7 calendar days.
- Assessment: triage for urgency, risk, and potential conflicts.
- Investigation: proportionate, impartial inquiry (which may involve Legal/HR/Finance or external specialists).
- Outcome & actions: substantiated concerns will lead to appropriate actions (e.g., remediation, disciplinary action, contract measures, reporting to authorities).
- Feedback: we will provide feedback to the reporter where lawful and appropriate, respecting privacy and due process.
We keep records secure and retain them only as long as necessary to meet legal and contractual requirements.
6) Confidentiality, anonymity & data protection
- We keep your identity confidential to the fullest extent possible and do not tolerate attempts to identify anonymous reporters.
- Personal data in reports is handled under our Privacy Policy and applicable laws. It may be processed in countries where Caribou operates, with safeguards in place.
7) Non-retaliation & good-faith reporting
- Strictly no retaliation. No one may dismiss, demote, harass, intimidate, threaten, withhold opportunities, or otherwise disadvantage a person because they raised a concern in good faith or assisted in an investigation.
- Good-faith means you believe the information is true, even if it later proves unfounded. Deliberately false or malicious allegations may lead to disciplinary action.
8) Interaction with other policies
Read this Policy alongside: