Whistleblowing

Whistleblowing Policy

At S.AI.L we believe that speaking up is not just a right — it is a responsibility. This policy outlines how you can raise concerns and the protections we provide to those who do so in good faith

1. Our commitment

S.AI.L is committed to the highest standards of ethical conduct and accountability. We recognise that individuals may sometimes become aware of wrongdoing, misconduct, or illegal activity within our organisation or in connection with our work

This policy exists to encourage and enable anyone connected with S.AI.L to raise serious concerns safely and confidentially, without fear of retaliation

2. Why this policy matters

Organisations that operate with integrity depend on people being willing to speak up when something is wrong. Whistleblowing is one of the most effective tools available for detecting and preventing wrongdoing

When concerns are raised early, they can be addressed before they cause lasting harm to individuals, clients, the organisation, or the public. This policy reflects our belief that raising concerns is an act of courage that deserves genuine protection and support

3. Who this policy covers

This policy applies to all individuals who interact with S.AI.L in any capacity, including:

  • Employees and directors
  • Contractors and consultants
  • Agency workers and temporary staff
  • Clients and former clients
  • Suppliers, partners, and third parties
  • Job applicants

You do not need to have a formal employment relationship with S.AI.L to use this policy

4. What constitutes wrongdoing

Wrongdoing under this policy includes any conduct that is illegal, unethical, or contrary to our values. This includes but is not limited to the matters set out in the Reporting concerns section below

You do not need to have proof of wrongdoing to make a report. A genuine, reasonable suspicion is sufficient. We ask only that you act in good faith

5. Primary reporting channel: Whistlelink

Our primary reporting channel is Whistlelink, a secure and independent platform specifically designed for whistleblowing disclosures. Whistlelink allows you to submit a report anonymously if you choose, and to maintain a confidential dialogue with our investigation team without revealing your identity

You can access Whistlelink at: https://execxai.com.whistlelink.com

We strongly encourage the use of Whistlelink as your first port of call. It provides the strongest protections for your identity and allows for a structured, documented investigation process

6. Reporting concerns

You may use Whistlelink to report concerns about any of the following:

  • Criminal activity, including fraud, bribery, or corruption
  • Failure to comply with legal or regulatory obligations
  • Miscarriages of justice
  • Health and safety risks or violations
  • Environmental damage or violations
  • Financial misconduct or misreporting
  • Breaches of data protection law or misuse of personal data
  • Violations of our Code of Conduct or Responsible AI principles
  • Harassment, discrimination, or bullying
  • Deliberate concealment of any of the above

This list is not exhaustive. If you are uncertain whether your concern falls within this policy, please submit a report and we will determine the appropriate course of action

8. AI assistance for report preparation

We understand that writing a whistleblowing report can be difficult. You may use AI tools to help you organise your thoughts, draft your report, or identify the relevant information to include

If you use AI assistance, please be aware that your prompts and inputs may be stored by the AI provider. Avoid entering personal information about yourself or others that you would not want retained. Whistlelink does not use AI to process your report

9. Recording conversations and gathering evidence

If you are considering recording conversations or gathering documentary evidence to support your report, we encourage you to seek independent legal advice before doing so. The legality of recording conversations varies by jurisdiction and context

You are not required to gather evidence before making a report. We will conduct our own investigation and gather evidence as appropriate

10. Protection against retaliation

S.AI.L takes a zero-tolerance approach to retaliation against anyone who raises a concern in good faith under this policy. Retaliation includes but is not limited to:

  • Dismissal, demotion, or disciplinary action
  • Threats or intimidation
  • Exclusion from meetings, projects, or opportunities
  • Negative performance reviews unrelated to genuine performance issues
  • Any other detrimental treatment connected to the whistleblowing report

Anyone found to have retaliated against a whistleblower will face serious disciplinary action, up to and including termination of their engagement with S.AI.L

If you believe you are experiencing retaliation, report it immediately through Whistlelink or by emailing compliance@execxai.com

11. Investigation process

All reports submitted under this policy will be taken seriously and investigated promptly. The investigation process involves the following stages:

Acknowledgment

We will acknowledge receipt of your report within five business days. If you have submitted anonymously via Whistlelink, you will receive acknowledgment through the platform

Initial assessment

We will assess the report to determine the appropriate course of action. This may involve requesting additional information from you through Whistlelink or by other means

Investigation

Where a formal investigation is warranted, it will be conducted by an appropriately independent person or team. The scope and method of investigation will depend on the nature of the concern raised

Communication

Where you have provided contact details or are contactable through Whistlelink, we will keep you informed of the progress and outcome of the investigation to the extent permitted by law and confidentiality obligations

Resolution

We will take appropriate action based on the findings of the investigation. This may include disciplinary action, process changes, regulatory reporting, or other remedial measures

12. Good faith reporting

This policy is designed for individuals who genuinely believe that wrongdoing has occurred or may occur. It is not intended for use in raising personal grievances, which should be addressed through our separate grievance process

Making a deliberately false or malicious report is a serious matter and may itself result in disciplinary action. However, if you raise a concern in good faith and it is not upheld following investigation, you will not face any adverse consequences

13. Support and resourcing

We recognise that raising a concern can be a stressful experience. S.AI.L is committed to supporting individuals who use this policy. If you would like to discuss your concern before submitting a formal report, you may contact compliance@execxai.com for an informal conversation

We also encourage you to seek independent legal advice if you are uncertain about your rights or the appropriate course of action

14. Regular review and updates

This policy will be reviewed at least annually and updated as necessary to reflect changes in law, regulation, or best practice. The current version of this policy is always available at www.execxai.com/whistleblowing

15. Contact information

Primary reporting channel: https://execxai.com.whistlelink.com

Policy questions and suggestions: compliance@execxai.com