Whistleblowing Policy
Purpose
NetworkX Technology Limited is committed to maintaining the highest standards of honesty, integrity, transparency, and accountability in all of its operations, including IT network solutions, technology consultancy, and recruitment services. This Whistleblowing Policy is designed to provide a structured and secure way for employees, contractors, candidates, clients, suppliers, and other stakeholders to raise concerns about serious misconduct or wrongdoing without fear of reprisal.
This policy supports our compliance with
- Public Interest Disclosure Act 1998 (PIDA)
- UK GDPR and Data Protection Act 2018
- EU Whistleblower Protection Directive (2019/1937)
- Relevant industry regulations and standards
Scope
This policy applies to
- All employees, directors, officers, agency staff, contractors, interns, and volunteers
- Recruitment candidates and placed workers
- Clients, vendors, partners, and service providers
- Any person interacting with the company who wishes to raise a concern
It covers reportable concerns in all our operational domains
- IT Network Solutions: Cybersecurity breaches, misuse of client systems, IT fraud
- Consultancy Services: Conflicts of interest, fraudulent consulting, data misuse
- Recruitment Services: Discrimination, bribery, falsified credentials
- General Business Conduct: Harassment, financial fraud, regulatory violations, health and safety breaches
Definitions
- Whistleblower: An individual who reports a concern in good faith.
- Reportable Concern: A reasonable belief that misconduct or a legal/ethical breach has occurred or is likely to occur.
- Retaliation: Any adverse action taken against a whistleblower, such as demotion, termination, or harassment.
Examples of Reportable Concerns
- Criminal activity (e.g., theft, bribery, fraud)
- Breaches of legal or regulatory obligations
- Breach of data protection or cybersecurity protocols
- Falsification of time records or financial statements
- Health and safety risks or environmental hazards
- Discriminatory practices or abuse in recruitment
- Unethical IT usage or professional misconduct
- Attempts to conceal wrongdoing
Reporting Channels
You can report a concern confidentially or anonymously through
Primary Internal Channels
Whistleblowing Officer
Email: info@networkxtech.com (Please mark correspondence “Attn: Whistleblowing Officer”).
Phone: 02039837422
Postal: Suite 310e, East Wing, Sterling House, Langston Road, Loughton, IG10 3TS (Please mark correspondence “Attn: Whistleblowing Officer”).
Alternative Internal Contacts
Investigation Process
- Acknowledgement: Concerns will be acknowledged within 48 hours.
- Initial Review: To determine the credibility and scope of the concern.
- Investigation: Led by an impartial investigator. This may involve:
- Interviews with involved parties
- Examination of documentation, logs, and evidence
- IT forensic analysis, if relevant
Timeline
- Minor issues resolved within 15 working days
- Complex cases updated every 30 days until closed
- Outcome: Written report summarising findings, corrective action, and lessons learned.
- All investigations will be conducted with discretion, professionalism, and confidentiality.
Protection from Retaliation
We strictly prohibit retaliation against any whistleblower acting in good faith.
Retaliation may include
- Demotion, dismissal, or loss of benefits
- Harassment, bullying, or isolation
- Denial of promotions or training opportunities
Protection Measures
- Identity kept confidential (unless legally required to disclose)
- Access to support resources (e.g., counselling, temporary job reassignment) Disciplinary action for those who retaliate
- Whistleblowers who feel victimised should contact HR or the Whistleblowing Officer immediately.
Confidentiality and Data Protection
All whistleblowing reports are treated with the strictest confidentiality. We protect the whistleblower's identity unless disclosure is required by law or necessary for an effective investigation. Data is stored securely and only accessible by authorised personnel Investigation details are disclosed on a need-to-know basis All records are retained per data retention policy under UK GDPR
False or Malicious Reports
Deliberately false or malicious allegations undermine the integrity of this policy. If an investigation finds that a report was knowingly fabricated, the individual responsible may be subject to disciplinary action, including dismissal or contract termination.
Training and Awareness
All employees and relevant contractors receive whistleblowing training at induction and annually thereafter Periodic refreshers via internal newsletters or awareness campaigns Policy included in employee handbooks and compliance materials
Legal Compliance
This policy is designed to comply with
- UK Public Interest Disclosure Act 1998
- UK GDPR & Data Protection Act 2018
- EU Whistleblower Protection Directive (2019/1937)
Sector-specific regulations including
- Financial Conduct Authority (FCA)
- Recruitment & Employment Confederation (REC) Code of Practice
- ISO 27001 (for information security)
Policy Review
This policy is reviewed
- At least biennially
- After any major legal, organisational, or regulatory changes
- Updates will be communicated to all staff and stakeholders.
Contact for Concerns
Email: info@networkxtech.com
Phone: 02039837422
