Whistleblowing Policy

This policy reflects the Public Interest Disclosure Act 1998 (PIDA), which amended the Employment Rights Act 1996. A protected disclosure under section 43B ERA 1996 relates to a reasonable belief that one or more of the following has occurred, is occurring, or is likely to occur:

• A criminal offence;
• Breach of a legal obligation;
• Miscarriage of justice;
• Danger to health and safety;
• Damage to the environment; or
• Concealment of any of the above.

This policy covers all OFORO LTD employees, officers, and engaged contributors (extended by section 43K ERA 1996), including our India-based contributor network. EU-based individuals are additionally covered by Directive (EU) 2019/1937 once we cross the headcount thresholds; we apply the equivalent standards now as a matter of best practice.

• Internal first: CEO at ceo@nxted.ai or the Chair of the Board.
• Confidential third party: [provider to be appointed] - independent channel with anonymity option.
• Prescribed person: the ICO, HMRC, or other prescribed regulator under the Public Interest Disclosure (Prescribed Persons) Order 2014, as relevant.
• External disclosure: permitted in limited circumstances under sections 43G-H ERA 1996.

Detriment against a person who has made a protected disclosure is itself unlawful (section 47B ERA 1996). We commit that no person will suffer dismissal, demotion, withholding of work, or any other adverse treatment for making a protected disclosure in good faith - including disclosures that turn out to be mistaken.

We protect the identity of a whistleblower to the maximum extent possible. Anonymous disclosures are accepted and investigated. Confidentiality clauses elsewhere in our agreements do not override the right to make a protected disclosure.

We acknowledge receipt within 7 calendar days and provide feedback within 3 months, in line with EU Directive 2019/1937 Article 9. Investigations are led by the CEO or, where the CEO is implicated, the Chair of the Board.

Knowingly false or malicious disclosures are not protected and may be subject to disciplinary action. Good-faith concerns based on reasonable belief are always protected, even if later shown to be incorrect.