External Whistleblowing Policy

Introduction

Billion Dollar Boy Limited (“BDB”) we are committed to operating with integrity, transparency and fairness in all employee, stakeholder and business relationships. BDB encourages employees and external stakeholders; including clients, suppliers, creators and members of the public to report any concerns related to any unethical, improper or illegal conduct in relation to BDB’s business operations.

This External Whistleblowing Policy (the “Policy”) provides a structured process for raising, reviewing and addressing whistleblowing concerns in a fair, timely and consistent manner.

What exactly is Whistleblowing

Whistleblowing refers to reporting suspected wrongdoing that is unethical, improper or illegal, conduct.  Examples of whistleblowing include, but are not limited to the following:

  • fraud, corruption or financial misconduct;
  • breaches of legal or regulatory obligations;
  • serious violations of ethical standards;
  • actions that endanger health, safety or the environment; and
  • harassment, misconduct or malpractice involving BDB employees or representatives.

Whistleblowing differs from raising a grievance, grievances typically relate to a personal complaint about a service related matter.  If your concern is about a service related disagreement rather than the types of misconduct set out in this Policy, please refer to BDB’s External Stakeholder Grievance Policy.

How to Report Concerns

BDB encourages external stakeholders to report any whistleblowing concerns as soon as is reasonably possible in the circumstances. There are a few ways to do so:

Direct Contact

If you feel comfortable, please report your concern directly to your primary BDB contact. If they cannot resolve the issue or if the concern is serious, it will be escalated appropriately to a member of BDB’s leadership team.

Confidential Reporting

For concerns requiring confidentiality, external stakeholders can report directly via email to [email protected] . Please include within your submission, the following:

  • a clear description of the concern;
  • any relevant dates, facts and supporting documents; and
  • whether or not you wish to remain anonymous.

BDB will at all times ensure that all concerns are handled sensitively and in a confidential manner.

Whistleblowing Investigation Process

Stage 1 – Acknowledgment and Initial Review

  • BDB will acknowledge receipt of the whistleblowing report within 5 business days.
  • An appropriate senior member of BDB’s leadership team will review the concern, ensuring impartiality and confidentiality.
  • Should further information be required, BDB may request additional details from the whistleblower.

Stage 2 – Investigation and Resolution

  • BDB shall conduct an impartial investigation based on the nature of the concern.
  • Following such investigation, BDB will take corrective action or escalate the matter to relevant authorities (as required).
  • BDB aims to complete all investigations within 15 business days, but complex matters may take longer.

Stage 3 – Final Response and Follow-Up

  • If the whistleblower has provided contact details, BDB will share an update on the outcome where legally permissible; and
  • BDB will take necessary measures to ensure that similar issues do not arise in the future.

Protection from Retaliation

BDB strictly prohibits any form of retaliation against external stakeholders who raise concerns in good faith.

  • Any act of retaliation, harassment or victimisation against a whistleblower will result in appropriate disciplinary action.
  • Whistleblowers do not need to provide proof, as raising a reasonable belief is sufficient.
  • All reports will be handled confidentially to the extent permitted by law.

External Disclosure

If you have followed this procedure and are still dissatisfied with the outcome, you may raise your concerns confidentially with the appropriate regulatory authority which can include HM Revenue & Customs, the Financial Conduct Authority, the Health & Safety Executive, the office of Fair Trading or the Environmental Agency, the police or a Member of Parliament.

All disclosures are protected under the Public Interest Disclosure Act 1998. The rules on external disclosure do not apply in circumstances where the disclosure is made to a qualified legal advisor to obtain legal advice relating to the disclosure. 

Policy Review and Updates

This Policy will be reviewed regularly as part of BDB’s commitment to responsible business practices and stakeholder engagement. BDB reserves the right to update or amend this Policy from time to time and/or as required by law.

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