Effective Date: 25.11.2024

1. Purpose
Bourgeon Ventures Ltd ("Bourgeon Ventures") is committed to maintaining the highest standards of integrity, transparency, and accountability. This Whistleblower & Speak-Up Policy is designed to encourage employees, contractors, and third parties to report suspected wrongdoing or unethical behaviour in a safe, confidential, and accessible manner, in line with the UK Public Interest Disclosure Act 1998 (PIDA).

2. Scope
This Policy applies to:

• Employees (current and former);

• Contractors, consultants, and agency workers;

• Third parties, including suppliers and partners;

• Any individual with knowledge of misconduct involving Bourgeon Ventures.

Disclosures under this policy may include:

• Criminal activity or fraud;

• Bribery, corruption, or breach of regulatory obligations;

• Unsafe practices or environmental harm;

• Discrimination, harassment, or bullying;

• Attempts to conceal wrongdoing.

3. Speaking Up – How to Report
Reports can be made in confidence via:

• Email: info@bourgeonventures.com;

• Post: Speak-Up Officer, Bourgeon Ventures Ltd, [Insert Registered Office Address];

• Anonymous Reporting: Anonymity is respected where permitted by law.

Please provide as much detail as possible to support the investigation.

4. Confidentiality & Non-Retaliation

• All disclosures will be treated with strict confidentiality to the extent permitted by law.

• No one will suffer detriment, dismissal, demotion, or any form of retaliation for making a report in good faith.

• Any retaliation will result in disciplinary action.

5. Investigation Process
Upon receipt of a report:

• An initial assessment will be conducted by the Speak-Up Officer or appropriate compliance lead;

• Where warranted, a full investigation will be launched;

• The whistleblower may be contacted for further information;

• Outcomes and corrective actions will be documented and, where possible, shared with the whistleblower.

6. Malicious Allegations
Deliberately false or malicious allegations will not be tolerated and may result in disciplinary action.

7. Training and Awareness
All employees will receive training on how to raise concerns. Awareness of this Policy is reinforced through onboarding, internal communications, and compliance briefings.

8. Monitoring and Review
This Policy is reviewed annually or in response to changes in legislation or organisational need. Updates will be communicated to all stakeholders.

Contact
For questions or guidance, contact:

Speak-Up Officer
Bourgeon Ventures Ltd
Email: info@bourgeonventures.com

By engaging with Bourgeon Ventures, you acknowledge the importance of a transparent, ethical culture and agree to uphold the principles of this Whistleblower & Speak-Up Policy.