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Playroll's Whistleblowing Policy

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  1. INTRODUCTION
    1. Playroll is committed to conducting its business with integrity and in an open, honest and ethical manner. In line with that commitment, Playroll expects staff, and others that we deal with, who have serious concerns about any aspect of Playroll’s work to come forward and voice those concerns. It is recognised that most cases will need to proceed on a confidential basis.
    2. Reporting of wrongdoing can be done without fear of victimisation, subsequent discrimination or disadvantage. This Policy is intended to encourage and enable staff to raise serious concerns within Playroll rather than overlooking a problem or 'blowing the whistle' outside.
  2. PURPOSE
    1. This Policy aims to:
      1. encourage Employees to report suspected unlawful or unethical behaviour as soon as possible;
      2. reassure Employees that their concerns will be taken seriously and investigated as appropriate and that their confidentiality will be safeguarded; and
      3. reassure Employees that when they report suspected unlawful or unethical behaviour in good faith, they will have the necessary protection.
  3. LOCAL LAWS AND REGULATIONS
    1. This policy applies globally, unless any aspect of the Policy is expressly limited by location or is not permitted by local law or regulation.
  4. REPORTING PERSONS
    1. This Policy applies to the following categories of “Reporting Persons”:
      1. all employees of Playroll (“Employees”);
      2. contractors and subcontractors of Playroll, as well as persons working under their supervision;
      3. suppliers of Playroll;
      4. shareholders and members of the Board of Directors;
      5. persons whose working relationship with Playroll has ended or is yet to begin (“Applicants”)
    2. The present Policy also applies to colleagues and relatives of Reporting Persons.
  5. IMPROPRIETIES AND BREACHES THAT CAN BE REPORTED
    1. Playroll encourages the provision of information by reporting persons  regarding offenses and suspected illegal behaviour, mismanagement incidents or serious  irregularities and omissions in connection with Playroll’s regulations, policy and procedures, financial  reporting and financial statements, whenever the reporting person reasonably believes that the  information disclosed is substantially true.
    2. Reporting Persons are therefore encouraged to make appropriate disclosures where there are reasonable grounds for believing that an impropriety has taken place or is likely to take place.
    3. The above covers the reporting of any serious wrongdoing, in good faith, including but not limited to:
      1. financial malpractice or fraud;
      2. criminal offenses;
      3. failure to comply with legal obligations;
      4. health and safety risks;
      5. environmental damage;
      6. bribery or corruption;
      7. serious breach of company policy;
      8. improper conduct or unethical behaviour;
      9. gross waste, mismanagement or abuse of authority; and
      10. concealment of any of the above.
  6.  PROCEDURE FOR REPORTING PERSONS
    1.  A Reporting Person may submit a report here through this form: https://forms.monday.com/forms/aefb480184c1ca8ba8ff40e5bbd14fcd?r=use1
    2. In order to facilitate the proper examination and assessment of the submitted reports, the  Reporting Persons are encouraged to provide all available information, including the facts giving  rise to the suspicion/concern related with the report, indicating the date and nature of the  event, the name(s) of the person(s) involved as well as potential witnesses, or other evidence,  including documents and locations.
    3. Playroll’s legal team will consider, investigate and address, where necessary, the incident in the report raised. The incident will be addressed confidentiality and escalated to the appropriate team if need be.
    4. The applicable Reporting Person shall assist the legal team with its investigations where requested.
    5. On conclusion of the investigation, the legal team will provide a written whistle blower report and a plan of action, if necessary.
    6. Reporting Persons are encouraged to report their concerns as soon as they become aware of them.
    7. The identity of the Reporting Person who discloses the incident shall remain confidential unless such Reporting Person waives confidentiality, or the identity of the Employee is vital for the incident to be resolved. In the event of the latter, the legal team shall ensure that the Reporting Person is provided with the necessary protection and that he/she is notified prior to disclosure.
    8. If the Reporting Person is an Employee, he/she is required to keep his/her disclosure confidential. It follows that such Employee shall not make such disclose public or known to his/her co-employees.
  7. EXTERNAL REPORTING  
    1. This Policy does not prevent the reporting of improprieties or relevant information to external channels maintained by competent authorities, in accordance with applicable laws.
  8. DISCIPLINARY ACTION FOR EMPLOYEES
    1. Playroll takes all reports made under this Policy seriously. Any Employee who knowingly makes a false or malicious allegation, or who provides information that they know to be untrue or misleading, will be subject to disciplinary action, up to and including termination of employment.
    2. Disciplinary action may also be taken against any Employee who:
      1. Refuses to cooperate or deliberately obstructs an investigation;
      2. Retaliates, victimises or threatens a Reporting Person or any other person participating in an investigation;
      3. Breaches the confidentiality of a whistleblowing report or investigation; or
      4. Fails to report a known serious impropriety or breach of this Policy when it would have been reasonable to do so.
    3. The severity of disciplinary measures will depend on the nature and seriousness of the misconduct, in accordance with Playroll’s disciplinary procedures and applicable laws.
    4. Conversely, no disciplinary or retaliatory action will be taken against any person who has raised a concern in good faith, even if the report is not substantiated upon investigation.
  9. PROTECTION FROM RETALIATION
    1. Playroll strictly prohibits any form of retaliation, reprisal or discrimination against a Reporting Person who raises a concern or provides information in good faith under this Policy.
    2. Any Employee or third party found to have retaliated against a Reporting Person, Playroll may take the appropriate action, including but not to disciplinary action.
    3. Examples of retaliation include, but are not limited to:
      1. dismissal;
      2. demotion;
      3. transfer;
      4. denial of promotion;
      5. reduction in pay or benefits;
      6. harassment; and
      7. ostracism.
    4. Playroll will take all reasonable steps to protect Reporting Persons from such conduct and will endeavour to remedy any adverse consequences that may result.
  10. CONFIDENTIALITY AND ANONYMITY
    1. All reports and investigations will be handled as confidentially as possible.
    2. Playroll will not disclose the identity of a Reporting Person without their explicit consent, unless required by law or necessary for the investigation.
    3. Anonymous reporting is permitted, but may limit the ability of Playroll to investigate or provide feedback to the Reporting Person.
  11. INVESTIGATION OUTCOME AND FEEDBACK
    1. Upon conclusion of an investigation, the Reporting Person will be informed, where necessary, appropriate and/or required by law, of the outcome or any actions taken, provided that this does not compromise confidentiality or the rights of others.
    2. Where an allegation is substantiated, Playroll will endeavour to take appropriate corrective or disciplinary measures.
  12. RECORD-KEEPING AND DATA PROTECTION
    1. All reports, investigation notes, and related documentation will be securely stored and handled in accordance with Playroll’s data protection policies and applicable privacy laws.
    2. Data will be kept only as long as necessary for the purposes of investigation, resolution, and compliance with legal or regulatory requirements.
    3. Access to such records will be limited to authorised personnel.
  13. AWARENESS AND ACCESS
    1. Playroll will host this Policy and the reporting link on its website and therefore it is easily accessible to all potential Reporting Persons.
  14. POLICY REVIEW AND GOVERNANCE
    1. This Policy will be reviewed annually, or sooner if required by changes in law or regulation, to ensure its effectiveness and continued alignment with best practices.
    2. Responsibility for maintaining and updating this Policy rests with Playroll’s Legal and Compliance teams.
  15. CONTACT INFORMATION
    1. For any questions or concerns regarding this Policy, please contact legal@playroll.com

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