TC-PLC-006 · Public Institutional Edition

Speak-Up, Whistleblowing and Non-Retaliation

Protected reporting, confidentiality, fair handling and zero tolerance for retaliation or interference.

This page presents externally relevant clauses from the approved Version 1.0 controlled policy. It is provided so clients and counterparties can understand the standards TrustCome applies. The controlled internal policy remains the authoritative operational instrument.
Application. These standards inform TrustCome's assessment of enquiries, authority, conduct, information use, third-party relationships and whether an engagement may be accepted, conditioned, paused, declined or ended. They do not replace applicable law or a signed agreement.

1. Purpose

1.1 This Policy establishes a protected, accessible and accountable system for raising, receiving, assessing, investigating and resolving concerns about suspected wrongdoing, misconduct, danger, abuse, concealment or retaliation.

1.2 Its purpose is to enable early intervention, protect persons who speak up, support fair treatment of all affected persons and preserve the integrity of TrustCome and those it serves.

2. Policy Statement

2.1 TrustCome encourages concerns to be raised as early as reasonably practicable and prohibits retaliation against any person who makes, considers making, supports, receives, assesses or investigates a report in good faith.

2.2 No commercial objective, personal relationship, seniority, confidentiality expectation or concern for reputation shall justify suppressing a legitimate report or compromising its independent handling.

20. Retaliation, Interference and Concealment

20.1 Reportable matters include retaliation or threatened retaliation, intimidation, pressure to remain silent, destruction or alteration of evidence, coaching of witnesses, interference with reporting channels and attempts to identify an anonymous reporting person without authority.

20.2 Any instruction to handle a concern outside approved governance arrangements shall be reported immediately.

27. Anonymous Reporting

27.1 Anonymous reports shall be accepted and assessed on their content, specificity, risk and available evidence rather than rejected because the reporting person is unknown.

27.2 TrustCome shall not attempt to identify an anonymous reporting person unless necessary, lawful, proportionate and authorised for a legitimate protective or investigative purpose.

28. Confidential Reporting

28.1 A reporting person may request that their identity be kept confidential. TrustCome shall honour that request to the greatest extent reasonably practicable and lawful.

28.2 Where identity disclosure may become necessary, the reporting person should be informed beforehand unless doing so would prejudice legal obligations, safety, evidence or the investigation.

31. External Reporting

31.1 A person may report externally where permitted or required by applicable law, including to a competent regulator, law-enforcement authority, professional body, inspector, court, ombudsman or other prescribed recipient.

31.2 TrustCome shall not retaliate against a person for making a lawful external report or cooperating with an external authority.

43. Need-to-Know Principle

43.1 Information concerning a report shall be shared only with persons who require it for protection, legal advice, investigation, decision, remediation, oversight or a binding obligation.

43.2 Curiosity, seniority, reputational interest or informal involvement does not create a need to know.

45. Limits of Confidentiality

45.1 Absolute confidentiality cannot be promised where disclosure is required by law, necessary to prevent serious harm, essential to procedural fairness or unavoidable for an effective investigation.

45.2 Any disclosure shall be limited to what is necessary and, where lawful and safe, discussed with the affected person beforehand.

51. Zero-Tolerance Standard

51.1 TrustCome prohibits direct, indirect, threatened, attempted or encouraged retaliation against a person because they raised, intended to raise, supported, received, assessed, investigated or gave evidence concerning a report in good faith.

51.2 Retaliation is a separate breach regardless of whether the original concern is substantiated.

57. Reporting Retaliation

57.1 Suspected retaliation shall be reported immediately through any protected channel, including directly to the independent or senior-level route.

57.2 A retaliation allegation shall not be returned solely to the manager or function alleged to be responsible.

62. Investigation Principles

62.1 Investigations shall be independent, competent, timely, proportionate, properly scoped, evidence-based, confidential and fair.

62.2 The purpose is to establish relevant facts and governance implications, not to validate a predetermined narrative or protect a preferred institutional outcome.

64. Procedural Fairness

64.1 Persons materially affected by allegations shall have a reasonable opportunity to understand and respond to the substance of the concerns, subject to lawful limits necessary to protect identity, safety, evidence or another person’s rights.

64.2 No finding shall be based solely on status, reputation, unsupported assumption or refusal to waive a lawful right.

65. Evidence and Standard of Assessment

65.1 Findings shall be based on the totality, reliability and consistency of available evidence, with contradictory and exculpatory information considered fairly.

65.2 The applicable internal standard shall be stated in the terms of reference and shall not be represented as a criminal or judicial determination.

72. Root Cause and Remediation

72.1 Material cases shall include consideration of root causes, control failures, cultural factors, incentives, supervision, governance design and previous warning signs.

72.2 Remediation shall have accountable owners, due dates, evidence of completion and independent verification proportionate to risk.

74. Communication with the Reporting Person

74.1 Where contact is possible, TrustCome shall provide proportionate updates at appropriate stages, taking account of confidentiality, legal privilege, fairness, security and the rights of others.

74.2 A reporting person shall not be required to discover that the matter has ended through rumour, public action or unexplained silence.

79. Post-Closure Protection

79.1 Retaliation monitoring and protective measures may continue after closure for a period proportionate to risk.

79.2 Post-closure review should consider delayed disadvantage, reference or renewal decisions, exclusion from opportunity, reputational attacks and adverse action attributed to unrelated reasons.

93. Breach and Consequences

93.1 Failure to report where required, retaliation, interference, concealment, confidentiality breach, evidence destruction, knowingly false reporting or misuse of the process may result in disciplinary, contractual, governance, civil, regulatory or criminal consequences as applicable.

93.2 Seniority, revenue contribution, political importance or relationship value shall not excuse breach.