Whistleblowing policy

1.1. At Newfoundland Diagnostics Ltd (“Newfoundland”) we are committed to maintaining high standards of integrity, openness, and accountability. This Whistleblowing Policy encourages all employees, workers, contractors, consultants, suppliers, and other relevant parties to raise concerns about wrongdoing, unethical behaviour, or illegal activities without fear of retaliation. It reflects the Public Interest Disclosure Act 1998 (which inserted whistleblowing protections into the Employment Rights Act 1996), as amended, and other UK legislation. This policy applies to all individuals working with Newfoundland regardless of their role or location.

1.2. Statutory whistleblowing protection applies to “workers” as defined in law. Where you are not a worker, we will still apply the protections in this policy to you as far as we can.

2.1. The purpose of this policy is to:

2.1.1. Support compliance with the whistleblowing provisions of the Employment Rights Act 1996, as amended by the Public Interest Disclosure Act 1998 and later legislation, by offering protection to whistleblowers.

2.1.2. Promote ethical practices by encouraging the reporting of illegal, unethical, or dangerous activities, including those related to bribery, modern slavery, data protection breaches, product safety, and discrimination.

2.1.3. Protect whistleblowers from retaliation or any other negative consequences for raising concerns that they reasonably believe are in the public interest.

3.1. This policy applies to all employees, workers, contractors, consultants, officers, interns, agency workers, suppliers, and third-party partners. It covers concerns relating to:

3.1.1. Criminal offences (for example fraud, bribery, or corruption, including under the Bribery Act 2010)

3.1.2. Non-compliance with legal or regulatory obligations (including data protection law such as the UK GDPR, and regulatory requirements for medical devices and diagnostic products)

3.1.3. Dangers to health and safety, including concerns about the safety, quality or performance of our products or services, inaccurate or falsified results, or inaccurate or falsified records or regulatory documents

3.1.4. Environmental risks

3.1.5. Human rights violations, including breaches of the Modern Slavery Act 2015

3.1.6. Discrimination or harassment, including sexual harassment

3.1.7. Financial mismanagement or misconduct

3.1.8. Any attempt to conceal any of the above

3.2. This policy is not intended for personal complaints about your own employment or working conditions. These should be raised under our grievance procedure. If a matter affects others or raises wider concerns, you may raise it under this policy.

4.1. Protection: A worker who makes a protected disclosure, meaning they reasonably believe the disclosure is in the public interest and tends to show one of the types of wrongdoing listed in section 3, is protected by law from dismissal and from detriment such as formal warnings or demotion. We apply the same standard of treatment to everyone covered by this policy.

4.2. Confidentiality: All concerns will be treated confidentially, and we will endeavour to keep the identity of the whistleblower anonymous where possible. However, if the investigation requires disclosure of identity, or disclosure is required by law, we will discuss this with the whistleblower first wherever we can.

4.3. Anonymous Reporting: Although we prefer that whistleblowers identify themselves, concerns can be raised anonymously. We will investigate anonymous reports to the extent possible, though anonymity may limit our ability to investigate fully.

4.4. No Retaliation: No whistleblower will suffer any form of retaliation for raising a concern that they reasonably believe to be true and in the public interest, even if the investigation does not confirm the allegation. Knowingly false or malicious allegations, however, may result in disciplinary action.

5.1. You can raise concerns through the following channels:

5.1.1. Manager or Supervisor: In most cases, raise concerns with your line manager.

5.1.2. Escalation: If the concern is serious, or if you feel uncomfortable reporting to your manager, you may escalate the issue to any Director.

5.1.3. If the concern involves a Director or the Designated Whistleblowing Officer, please raise it with another Director.

5.2. External Reporting: Where internal reporting does not resolve the concern, or if you believe the issue involves significant wrongdoing, you may report to an external body (a “prescribed person”), for example:

5.2.1. The Health and Safety Executive, for health and safety concerns

5.2.2. The Information Commissioner’s Office, for data protection concerns

5.2.3. The Medicines and Healthcare products Regulatory Agency, for concerns about medical devices

5.2.4. Other regulators relevant to the matter, such as the Financial Conduct Authority

5.3. Protect (formerly Public Concern at Work), a whistleblowing charity that can offer independent guidance on reporting: https://protect-advice.org.uk

5.4. Concerns about modern slavery can also be raised with the Modern Slavery and Exploitation Helpline on 08000 121 700.

5.5. All reports should include:

5.5.1. Details of the concern

5.5.2. Key facts and dates

5.5.3. Names of individuals involved

5.5.4. Any evidence supporting the concern

6.1. Upon receiving a whistleblowing report:

6.1.1. Acknowledgement: You will receive confirmation that your concern has been received within 5 working days.

6.1.2. Investigation: An impartial investigator will be assigned, and a thorough, confidential investigation will be conducted.

6.1.3. Feedback: You will be kept informed of the progress of the investigation, although specific details may remain confidential.

6.1.4. Outcome: Upon conclusion, you will be informed of the outcome and any actions taken. If you are unsatisfied with the outcome, you may escalate the concern to a senior executive or an external body.

6.2. If misconduct is discovered, appropriate corrective action will be taken, including disciplinary action, dismissal, or reporting to external authorities where required.

7.1. All personal data related to whistleblowing reports will be handled in accordance with the UK GDPR. This includes ensuring that data is:

7.1.1. Processed fairly and lawfully

7.1.2. Kept secure and confidential

7.1.3. Accessed only by individuals involved in the investigation

8.1. If you raise a concern in line with this policy, you will be protected under this policy and, where you are a worker, under the Employment Rights Act 1996 as amended. Any form of retaliation or detrimental treatment for whistleblowing will be treated as a disciplinary matter and could result in serious consequences, including dismissal.

9.1. As part of our compliance with the Bribery Act 2010, all concerns related to bribery, corruption, or unethical business practices should be reported promptly. This includes any form of offering, giving, or receiving bribes. Failure to report such activity may lead to disciplinary action.

10.1. In line with the Modern Slavery Act 2015, we are committed to taking reasonable steps to ensure that modern slavery and human trafficking do not take place in our supply chains or any part of our business. Whistleblowers are encouraged to report any concerns relating to exploitation, forced labour, or human rights abuses.

11.1. In some cases, whistleblowers may feel it is necessary to take their concerns to an external body, such as a regulator or legal authority. In such cases, the whistleblower is encouraged to seek advice from an independent organisation such as Protect. While raising concerns internally is preferred, workers are protected by law if they make disclosures that meet the legal requirements, including disclosures to the appropriate external authorities. Wider disclosures, such as to the media, are subject to stricter conditions, so please take advice first.

12.1. This policy will be reviewed annually by the Board to ensure compliance with UK laws and regulations, including changes to whistleblowing legislation, the Bribery Act, the Modern Slavery Act, the UK GDPR, and other relevant legislation. Whistleblowing reports will be monitored, and the outcomes presented to the Board (in anonymised form where appropriate) to ensure continuous improvement and compliance with our legal obligations.

Frequency of Review: Annually
Approved by Michael Hodnett, Director
Date: 29th October 2026