Whistleblowing Policy

1. Purpose

TRM Flex Limited is committed to operating with integrity. This policy enables anyone working with us — staff, self-employed contractors, suppliers, clients and members of the public — to raise concerns about suspected wrongdoing without fear of retaliation. It is written with reference to the Public Interest Disclosure Act 1998 and the relevant provisions of the Employment Rights Act 1996 (sections 43A–43L).

2. Scope

This policy applies to disclosures about:

• a criminal offence;
• a failure to comply with a legal obligation;
• a miscarriage of justice;
• danger to the health or safety of any individual;
• damage to the environment;
• bribery or corruption;
• fraud, theft or financial misconduct;
• safeguarding concerns about a child or vulnerable adult;
• deliberate concealment of any of the above.

It is not a route for personal grievances about your own engagement with TRM Flex; those should be raised through normal contact with us at hello@trmflex.com or via our Complaints process.

3. Protection from detriment

A “qualifying disclosure” under the Public Interest Disclosure Act 1998 is one that, in the reasonable belief of the person making it, is made in the public interest and tends to show one or more of the matters in section 2.

We will not subject anyone making a qualifying disclosure in good faith to any detriment as a result. This commitment applies regardless of whether the concern turns out to be substantiated, provided the person reasonably believed it at the time. Workers who make a protected disclosure under the Act are protected by law against dismissal and other detriment.

4. How to raise a concern

4.1 Internal route (preferred first step)

Email hello@trmflex.com with the subject prefix [Whistleblowing]. Where possible please include:

• a description of the concern;
• names and dates where known;
• any documents or screenshots that support the concern;
• whether you wish to remain anonymous (we will respect this where the law allows).

4.2 If the concern involves the recipient

If your concern relates to the recipient of the email above, address it directly to the company's registered office marked “Strictly Private & Confidential — Whistleblowing”:

TRM Flex Limited, C/O Eaccounts, Ground Floor Cardigan House, Castle Court, Swansea, SA7 9LA.

4.3 External “prescribed person” route

You may make a protected disclosure directly to a relevant “prescribed person” listed by the UK Government, including:

• the Information Commissioner's Office (data protection matters): ico.org.uk;
• HM Revenue & Customs (tax matters): gov.uk/hmrc;
• the Health and Safety Executive: hse.gov.uk;
• the Financial Conduct Authority where regulated activity is involved.

The independent charity Protect (protect-advice.org.uk) provides free confidential advice on whistleblowing.

5. How we handle a disclosure

1. We will acknowledge receipt within 5 business days.
2. An appropriate person who has no involvement in the matter will assess and investigate.
3. We will keep your identity confidential to the maximum extent the law and the investigation allow.
4. We aim to provide a substantive response within 30 days; complex matters may take longer, in which case we will keep you informed.
5. Where wrongdoing is found, we will take appropriate corrective action and, if required, report it to the relevant authority.

6. Anonymous disclosures

We accept anonymous disclosures and will investigate so far as practicable. Anonymous disclosures can be harder to investigate fairly; providing contact details (which we will keep confidential) helps us reach a sound conclusion.

7. Bad faith and false allegations

Knowingly making a false allegation is not protected by this policy and may lead to disciplinary or contractual action and, in serious cases, civil or criminal proceedings.

8. Records and review

Whistleblowing records are kept securely on a strictly need-to-know basis and retained in line with our records retention schedule. This policy is reviewed at least every 12 months.