Whistleblower Policy

Good-Loop is committed to maintaining the highest standards of integrity, and takes very seriously all good faith complaints and concerns regarding accounting, data, legality, and internal controls and auditing matters. Our policies and practices have been developed to maintain the highest business, legal and ethical standards.

Therefore, it is policy for employees, when they reasonably believe that illegal activity or questionable accounting, data, or auditing practices have occurred or are occurring, to report those concerns (on an anonymous basis, if the employee so desires). All good faith reports will be taken seriously and will be promptly investigated. All information disclosed during the course of the investigation will remain confidential, except as necessary to conduct the investigation and take any remedial action.

Any employee reporting concerns of this nature has a lawful right to raise these concerns without fear of harassment, discrimination or retaliation. The Company strictly prohibits discrimination, retaliation or harassment of any kind against any employee who, based on the employee's reasonable belief that such conduct has occurred, reports that information pursuant to this Policy.

What Counts for Whistleblowing?

From https://www.gov.uk/whistleblowing:

Complaints that count as whistleblowing

You're protected by law if you report any of the following:

• a criminal offence, for example fraud
• someone's health and safety is in danger
• risk or actual damage to the environment
• a miscarriage of justice
• the company is breaking the law, for example does not have the right insurance
• you believe someone is covering up wrongdoing

Complaints that do not count as whistleblowing

• Personal grievances (for example bullying, harassment, discrimination) are not covered by whistleblowing law, unless your particular case is in the public interest.

Report these under your employer's grievance policy.

Contact the Advisory, Conciliation and Arbitration Service (Acas) for help and advice on resolving a workplace dispute.

Reporting Complaints

Duty to Report

If you have reason to believe that you have become aware of questionable accounting, data, internal controls or auditing matters, or the reporting of fraudulent financial information, you must immediately report those facts pursuant to this Policy. Examples of matters requiring you to make a report include (but are not limited to) the following:

• Fraud or deliberate error in the preparation, evaluation, review or audit of any financial statements.
• Fraud or deliberate error in the recording and maintaining financial records.
• False statement, to or by a senior officer or accountant regarding financial matters.
• The existence of side agreements with customers, distributors or resellers which could be an undisclosed conflict of interest.
• Violation of laws against trading on inside information, or any non-compliance with any insider trading policy.
• Deviations from full and fair reporting of finances.

Procedures to Make a Report

Employees should submit concerns (confidentially and anonymously, if they wish) in any of the following ways:

• By email to CEO, Amy Williams
• Or by email to any member of the Board of Directors
• Or by post to the company's registered office

Treatment of Complaints

1. Receipt of complaints will be acknowledged to the sender, within a reasonable period following receipt, if appropriate information for response is supplied.

2. All complaints shall be reviewed by the Board, who may appoint someone to investigate as appropriate.

3. Confidentiality will be maintained to the fullest extent possible, consistent with the need to conduct an adequate review and applicable laws.

4. Reprisal, threats, retribution or retaliation in any way against any person who has in good faith made a complaint or reported a good faith concern, or against any person who assists in the investigation of such complaint or concern, is strictly prohibited.

5. Subject to appropriate confidentiality protection, the Board will report the results of any investigation regarding a complaint, including any corrective actions taken, to the person making the complaint, if appropriate information for response was supplied, maintaining the anonymity of the person making the complaint to the fullest extent possible.