Whistleblowing Policy

1. Policy Statement 

Plug and Play Limited, trading as Plug & Play Design ("the Company", "we", "us"), is committed to the highest standards of openness, honesty, and accountability. We want everyone who works for or with us to feel able to raise genuine concerns about malpractice, wrongdoing, or risk without fear of detriment. 

This policy is intended to support, and be read alongside, our other compliance policies, including the Modern Slavery and Human Trafficking Policy and the Anti-Bribery and Corruption Policy, both of which refer individuals to this policy when raising a concern. 

2. Purpose and Scope 

This policy applies to: 

• All directors, employees, and workers of Plug and Play Limited and Plug & Play Design, whether permanent, fixed-term, or temporary; 
• All contractors, freelancers, and consultants engaged by the Company; 
• Suppliers and other third parties who become aware of a concern relating to the Company. 

This policy is intended for genuine concerns about wrongdoing, risk, or malpractice. It is not the appropriate channel for personal grievances for example, a dispute about your own treatment at work. 

3. What is a Whistleblowing Concern? 

A whistleblowing concern (also known as "making a disclosure" or "blowing the whistle") is raising information about suspected wrongdoing or risk that affects others, such as clients, colleagues, the public, or the Company itself. This can include, but is not limited to: 

• A criminal offence, such as fraud or bribery; 
• A breach of a legal or regulatory obligation, including data protection or health and safety law; 
• Modern slavery, human trafficking, or exploitation of workers; 
• Danger to the health and safety of any individual; 
• Damage to the environment; 
• Financial malpractice, mismanagement, or misuse of Company funds or assets; 
• Deliberate concealment of any of the above. 

You do not need to have firm evidence to raise a concern; a genuine, reasonable suspicion is enough. You should not, however, make an allegation that you know to be false. 

4. How to Raise a Concern 

Concerns should be raised as early as possible. In most cases, you should raise your concern with: 

• Any member of the Management Team, in person, by phone, or in writing, in confidence 

Where possible, please set out what happened, when and where it happened, who was involved, and why it concerns you. You are welcome to raise a concern verbally in the first instance, but a written note helps ensure it is investigated accurately. 

5. Confidentiality and Anonymity 

We will treat all concerns in confidence and make every effort not to reveal the identity of the person raising a concern, except where required by law, regulation, or where necessary to properly investigate the matter (and in that case, only with the individual's knowledge wherever possible). 

You are welcome to raise a concern anonymously. However, anonymous concerns are harder to investigate thoroughly and we cannot follow up with you for further information or update you on the outcome, so we would encourage you to identify yourself where you feel able to. 

6. Protection Against Retaliation 

The Company will not tolerate any form of detriment, retaliation, or victimisation against anyone who raises a genuine concern in good faith under this policy, even if the concern turns out, after investigation, to be mistaken. This applies regardless of whether the concern relates to a colleague, a manager, a director, or the Company itself. 

Any employee found to have subjected another individual to retaliation for raising a concern in good faith will face disciplinary action, up to and including dismissal. This protection does not extend to someone who raises a concern maliciously or that they know to be false. 

7. How We Will Respond 

On receiving a concern, we will: 

• Acknowledge receipt within [5 working days]; 
• Assess what type of investigation is appropriate and, where possible, agree this with you; 
• Investigate promptly, proportionately, and as confidentially as the circumstances allow; 
• Where you have identified yourself, provide an update on the outcome, subject to any legal or confidentiality constraints (for example, we may not be able to share details of any disciplinary action taken against another individual); 
• Take appropriate action based on the outcome of the investigation, which may include referral to external authorities such as the police, the Health and Safety Executive, the Information Commissioner's Office, or the Serious Fraud Office. 

8. External Disclosure 

We hope that this policy gives you confidence to raise concerns internally in the first instance. In some circumstances, UK law (the Public Interest Disclosure Act 1998, as incorporated into the Employment Rights Act 1996) protects workers who raise a qualifying concern externally, for example with a relevant regulator. If you are considering raising a concern outside the Company, we would encourage you to first discuss this with the Management Team or seek independent advice (for example from Protect, the UK whistleblowing charity, at www.protect-advice.org.uk), as external disclosure without good reason may affect the legal protection available to you.