Whistleblowing
Policy.
This policy provides a route for employees, contractors, clients, suppliers and other stakeholders to raise genuine concerns about suspected wrongdoing connected to Pintop Technologies Limited.
Genuine concerns should have a safe route to be heard.
Pintop is committed to lawful, ethical and accountable conduct across its business, products, projects and relationships.
This policy provides a framework for reporting suspected wrongdoing where the concern affects Pintop, its people, clients, systems, finances, data or business relationships.
Whistleblowing is different from a personal grievance. A personal complaint about an individual employment, payment or contractual matter may be more appropriately handled through the relevant grievance, management, support or contractual process.
Concerns that may be
reported.
A report may concern past, current or likely future conduct where the reporter reasonably believes the matter should be reviewed.
Unlawful conduct
Suspected breaches of applicable law, regulatory obligations, court orders or legally binding duties.
Bribery and corruption
Improper payments, inducements, kickbacks, concealed benefits or misuse of influence.
Fraud and financial irregularity
Theft, falsified records, misappropriation, dishonest accounting, unauthorised transactions or concealed financial activity.
Privacy or security misconduct
Deliberate misuse of personal data, concealment of a breach, unauthorised access or disregard of applicable security responsibilities.
Harassment or serious misconduct
Serious discrimination, harassment, bullying, victimisation or abuse affecting another person.
Health and safety risk
Conduct or conditions creating an unreasonable danger to employees, contractors, clients or members of the public.
Abuse of authority
Misuse of position, conflicts of interest, improper preferential treatment or misuse of Pintop resources.
Concealment
Attempts to hide, destroy evidence of or prevent the reporting or investigation of serious wrongdoing.
Serious policy violations
Conduct materially inconsistent with Pintop’s legal, ethical, privacy, financial or operational policies.
Raise the concern clearly and in good faith.
Send a written report through Pintop’s contact route or by email. Mark the message as a confidential whistleblowing report and avoid sending unnecessary personal or sensitive information.
A factual report is easier to assess and investigate.
Provide information you reasonably believe to be true. You do not need to prove the case before raising a concern.
Confidentiality and protection from
retaliation.
Reports should be handled carefully, with information limited to people who reasonably need it for assessment, investigation, legal advice or corrective action.
Confidential handling
Pintop will seek to protect the reporter’s identity and the contents of the report. Disclosure may still be necessary where required by law, needed for a fair investigation or required to protect another person’s rights.
No retaliation for good-faith reporting
A person should not be dismissed, threatened, intimidated, disadvantaged or otherwise penalised because they raised a genuine concern or participated honestly in an investigation.
How a report may be
handled.
The exact process depends on urgency, seriousness, available evidence, conflicts of interest and whether another authority should be involved.
Receive and secure
Record the concern, restrict unnecessary access and preserve information supplied with the report.
Initial assessment
Determine whether the matter falls within this policy, whether immediate protective action is needed and which handling route is appropriate.
Address conflicts
A person who is implicated in or materially connected to the concern should not control the investigation or final assessment.
Gather and test evidence
Relevant documents, records, system information and witness accounts may be reviewed in a fair and proportionate manner.
Allow a fair response
A person whose conduct is under review should be given an appropriate opportunity to respond, subject to evidence preservation and safety considerations.
Determine the outcome
The matter may be closed, referred, escalated or lead to corrective, contractual, operational, policy or legal action.
Communicate appropriately
Where contact details are available, the reporter may receive a general update or outcome subject to privacy, employment, contractual and legal restrictions.
An anonymous report can still be reviewed.
Pintop may assess a report without the reporter’s name where the information provided is sufficiently specific and credible.
Outcomes, records and
accountability.
Relevant records are maintained to support fair handling, legal obligations, corrective action and organisational learning.
Report record
The date, subject, reporting route and initial scope may be recorded without unnecessary personal detail.
Investigation record
Relevant evidence, decisions, conflicts, findings and investigation steps may be documented.
Outcome
The matter may be substantiated, partly substantiated, unsubstantiated, referred or closed because evidence is insufficient.
Corrective action
Appropriate action may address systems, access, contracts, controls, policies, training or management oversight.
Restricted access
Whistleblowing records are handled as confidential information and accessed only for an appropriate purpose.
Retention
Records are retained only for the period reasonably required for accountability, legal obligations, disputes or related follow-up.
This policy does not prevent lawful reporting to an appropriate authority.
A person may contact a regulator, law-enforcement body, court, professional adviser or another appropriate external authority where they reasonably consider that route necessary.
Need to report suspected wrongdoing connected to Pintop?
Provide a clear factual account, the people or systems involved, relevant dates and any supporting information already lawfully available to you.
Related conduct and
governance documents.
These documents provide further information about ethical conduct, data protection, system use and workforce privacy.
This Whistleblowing Policy is effective from 1 Aug 2026.