Privacy Policy

Policy Statement

Uksan GH LLP is committed to conducting its business with honesty, integrity, and accountability. We encourage a culture of openness and transparency where all employees, partners, contractors, and stakeholders feel confident and safe in raising genuine concerns about malpractice, illegal acts, or unethical behaviour without fear of retaliation or victimisation.

This policy provides a framework to enable individuals to raise concerns internally and at a high level, ensuring they are taken seriously and investigated appropriately and confidentially.

This policy applies to all employees, partners, consultants, contractors, agency workers, and volunteers working for or on behalf of Uksan GH LLP.

Aim of the Policy

• To encourage individuals to report suspected wrongdoing as early as possible.
• To provide clear channels for raising concerns.
• To reassure individuals that they can raise concerns without fear of reprisal.
• To ensure concerns are treated seriously and investigated promptly and confidentially.
• To provide feedback on the outcome of investigations, where appropriate.

What is Whistleblowing? (Scope)

Whistleblowing is the disclosure of information which relates to suspected wrongdoing or dangers at work. These concerns typically relate to the following, but are not limited to:

• Criminal offences: e.g., fraud, bribery, corruption, theft.
• Failure to comply with a legal obligation: e.g., breach of financial or professional regulations.
• Miscarriages of justice.
• Endangerment of health and safety: of any individual.
• Damage to the environment.
• Unethical conduct: e.g., violation of company ethics policies.
• Deliberate concealment of information relating to any of the above.

This policy is not a substitute for:

• Grievances: Personal complaints about your own employment terms or conditions (e.g., pay, workload, bullying by a colleague) should be raised under the Grievance Procedure.
• Complaints about customers/suppliers: These should generally be raised with your line manager.

If you are unsure whether your concern is a whistleblowing matter, you are encouraged to raise it anyway under this policy.

Safeguards: Protection for the Whistleblower

Uksan GH LLP will not tolerate the harassment or victimisation of anyone raising a genuine concern in good faith. This includes:

• Protection from Retaliation: Any individual who retaliates against someone who has raised a concern in good faith will be subject to disciplinary action, which may include dismissal.
• Confidentiality: All concerns will be treated with the utmost confidentiality. Your identity will not be disclosed without your consent, unless required by law (e.g., by the police in a criminal investigation).
• Anonymous Reports: We encourage individuals to put their name to a report, as anonymous concerns are often more difficult to investigate. However, anonymous reports will be considered at the discretion of the company, taking into account the seriousness of the issue, the credibility of the information, and the prospects of conducting a fair investigation.
• Good Faith: Individuals are expected to raise concerns in good faith. While they do not need to prove the truth of their allegation, they must have a reasonable belief that the information is true. Maliciously making false allegations may be treated as a disciplinary matter.

How to Raise a Concern (The Process)

Step 1: Internal Reporting

• We encourage you to raise your concern with your immediate line manager in the first instance. If this is not appropriate (e.g., if the concern is about your manager), you should raise it with one of the following designated individuals:
• Designated Whistleblowing Officers:

Anand Singh      Partner               email anand@uksangroup.com

                             Nandita Dalal     Partner               email nandita@uksangroup.com

You can raise your concern in person or in writing (email or letter).

Step 2: What to Include

To help us investigate effectively, please provide as much information as possible, including:

• Your name and contact details (unless wishing to remain anonymous).
• The background and history of the concern.
• The names of individuals involved.
• The dates, times, and locations of incidents.
• Any evidence you have (e.g., documents, emails).
• Whether you have already raised the matter and with whom.

Step 3: Investigation

• Upon receiving a concern, the designated officer will make an initial assessment to determine the scope and nature of the investigation required.
• The investigation will be conducted by an appropriate, impartial person or team. This may involve interviewing individuals, reviewing documents, and collecting evidence.
• We will aim to acknowledge your concern within 5 working days and provide an estimated timeframe for the investigation. The complexity of the case will determine how long the investigation takes.

Step 4: Outcome and Feedback

• Once the investigation is complete, the findings will be reported to the Managing Partner or a designated committee.
• Appropriate action will be taken, which may include disciplinary proceedings, changes to company procedures, or reporting the matter to an external authority (e.g., the police, a regulator).
• While we cannot always disclose full details of the outcome due to confidentiality and legal reasons, we will provide you with feedback on the general outcome, where appropriate and possible.

External Disclosure

We strongly encourage you to use this internal policy first. However, we recognise that in some rare circumstances, it may be necessary to raise the concern with an external body, such as a prescribed regulator (e.g., the Financial Conduct Authority, Health and Safety Executive), or in extreme cases, the media.

• Legal protection for whistleblowers applies provided the disclosure is made:

                             In good faith.

                             With a reasonable belief that the information is substantially true.

                             Not for personal gain.

              In the public interest.

We advise that you seek independent legal advice before making an external disclosure.

Responsibilities

• All Individuals: To act with integrity and raise genuine concerns through the appropriate channels.
• The Whistleblower: To raise concerns promptly, in good faith, and without malice.
• Managers & Designated Officers: To treat all concerns seriously, ensure confidentiality, and oversee a fair and prompt investigation.
• The Company (Uksan GH LLP): To uphold this policy, protect whistleblowers from retaliation, and act on the findings of investigations.

Policy Review

This policy will be reviewed annually by the Managing Partner to ensure it remains fit for purpose and compliant with legislation. All staff will be notified of any changes.