MARYADI LIMITED –

WHISTLEBLOWING FRAMEWORK

Document Control

  • Author: Adil Yermekov
  • Approval Authority: Mary Calistri
  • Publication: March 2025 (v1.0)
  • Next Review: March 2026 (v2.0)
  • Review Cycle: Annual

EXECUTIVE SUMMARY

At MARYADI LIMITED, we uphold the highest standards of transparency, integrity, and accountability. This framework establishes protocols enabling staff members to responsibly voice concerns about potential misconduct without fear of reprisal.

While employment contracts generally require confidentiality regarding company affairs, individuals who discover evidence of serious wrongdoing should have secure channels to report such information independently of management structures.

The Public Interest Disclosure Act (1999) provides legal safeguards for employees against dismissal or penalties resulting from disclosure of specific serious concerns. MARYADI LIMITED fully endorses these provisions to ensure no staff member feels disadvantaged when raising legitimate issues.

This framework specifically addresses the reporting of malpractice or impropriety. It is not intended to question standard business decisions or to replace existing procedures for addressing harassment, complaints, or disciplinary matters. With these whistleblowing procedures in place, staff are expected to utilize internal reporting mechanisms rather than air concerns externally.

REPORTABLE CONCERNS

This framework applies to concerns that serve the public interest and warrant investigation. Such concerns may include but are not limited to:

  • Fraudulent activities or financial impropriety
  • Non-compliance with legal obligations or statutory requirements
  • Health, safety, or environmental hazards
  • Unlawful conduct
  • Unethical behavior or professional misconduct
  • Concealment attempts regarding any of the above

WHISTLEBLOWER PROTECTIONS

Good Faith Requirement

Protection extends to company employees who disclose concerns provided that:

  • The disclosure is made in good faith
  • The individual reasonably believes the information indicates malpractice or impropriety
  • The report is submitted to an appropriate designated person

Note that protection from internal disciplinary procedures is not available to those who choose not to follow this process. Deliberately false or malicious allegations could potentially result in legal action by the accused parties.

Confidentiality Guarantee

All disclosures will be handled with strict confidentiality and sensitivity. The reporting individual’s identity will remain confidential to the extent that it does not impede investigation. However, the investigative process may ultimately reveal information sources, and statement provision by the whistleblower may become necessary as evidence.

Anonymity Considerations

While this framework encourages individuals to identify themselves when making disclosures, anonymous reports may be considered at company discretion. Evaluation factors include:

  • Issue seriousness
  • Concern credibility
  • Possibility of confirming allegations through traceable sources

False Reporting Consequences

Individuals making good-faith allegations that subsequent investigation does not substantiate will face no adverse action. However, disciplinary measures may apply to those making deliberately false, malicious, or persistent unfounded allegations. Whistleblowers should exercise due diligence regarding information accuracy.

DISCLOSURE PROCEDURE

Employees receiving complaints must promptly forward information to the appropriate investigating officer:

  • Director Adil Yermekov will investigate malpractice claims unless the allegations involve or relate to the Director.

In cases where complaints involve the Director, whistleblowers may approach designated independent contacts who can advise on both internal and external reporting options under relevant legislation:

  • [Alternative Contact Name 1]
  • [Alternative Contact Name 2]

If evidence suggests criminal activity, the investigating officer must inform police authorities. MARYADI LIMITED will ensure internal investigations do not interfere with formal police inquiries.

INVESTIGATION TIMELINE

Given the varied nature of potential complaints, which may require internal investigation and/or police involvement, specific timelines cannot be predetermined. However, investigating officers must:

  1. Conduct investigations expeditiously without compromising thoroughness
  2. Promptly acknowledge receipt of complaints in writing
  3. Provide written reports to complainants regarding investigation outcomes and proposed actions
  4. Furnish written updates on prolonged investigations, including projected completion timeframes

All communication with complainants must be in writing and delivered to their residential address.

INVESTIGATION METHODOLOGY

Investigating officers will follow this procedural framework:

  1. Obtain comprehensive details and clarifications regarding the complaint
  2. Notify the implicated staff member as soon as practicable, informing them of their right to representation in subsequent interviews
  3. Consider potential involvement of company auditors and law enforcement, consulting with Chairman/Chief Executive as appropriate
  4. Thoroughly investigate allegations, collaborating with relevant individuals/bodies as needed
  5. Formulate a judgment regarding complaint validity, documented in a detailed written report containing investigation findings and decision rationale
  6. Submit the report to the Chief Executive or Chairman
  7. The Chief Executive/Chairman will determine appropriate action, potentially invoking disciplinary or other company procedures if the complaint is substantiated
  8. Keep complainants informed of investigation progress and outcomes when appropriate
  9. If relevant, provide outcome documentation to Company Auditors for procedural review

If complainants are dissatisfied with the investigating officer’s handling of their concern, they may confidentially escalate the matter to the Chief Executive/Chairman or designated persons described above.

If investigations find allegations unsubstantiated and all internal procedures have been exhausted, but the complainant remains dissatisfied, MARYADI LIMITED acknowledges employees’ and former employees’ legal rights to disclose information to prescribed authorities (such as the Health and Safety Executive, Audit Commission, or utility regulators) or elsewhere when justified.

ADDITIONAL RESOURCES

MARYADI LIMITED directs individuals to the NSPCC website for comprehensive information on whistleblowing. NSPCC contact options include:

  • Telephone: 0808 800 5000
  • Email: help@nspcc.org.uk
  • Online form submission via their website