Speak Up Policy

Introduction

Our Values

A key Value of Media.Monks is Integrity and Responsibility – which link to our Core Principle of Authenticity, Integrity and the highest Ethical Standards in our business dealings.

These apply in all our dealings within Media.Monks, and when we work with clients, suppliers and in our communities.

Purpose

We expect the highest ethical standards across our businesses, so there may be occasions where any of our Colleagues wish to report suspected wrongdoing. The aim of this Policy is to provide mechanisms for reporting and investigating such concerns. This Policy is to support:

  1. A culture of authenticity and responsibility;
  2. The reporting of suspected wrongdoing, knowing that concerns will be taken seriously and investigated as appropriate, whilst respecting confidentiality;
  3. The methods of raising a concern; and
  4. The principle of non-retaliation.

Scope

This Policy applies to S4Capital plc and to all subsidiaries in which it holds, directly or indirectly, a majority shareholding or exercises effective control, collectively called ‘Media.Monks’ or the ‘Company’.

This Policy also applies to all individuals working full time or part time at all levels within the Company, as well as those performing work for the Company such as agency workers, self-employed contractors, part-time and fixed-term workers, interns, collectively referred to as ‘employees’.

Principles

Anonymity

We encourage people to put their name to any reports they make, but if they prefer to remain anonymous their reports will still be taken seriously and investigated as far as possible.  Note that anonymous reports may be more difficult to investigate, so we would encourage employees making reports to include as much factual information as possible.

Confidentiality 

We will treat, as far as is reasonably practical, all reports in a confidential and sensitive manner.  The identity of the employee making the report will not be disclosed without explicit consent to anyone beyond the staff members who receive and follow up on the report. Although the identity of the reporter will be kept confidential, it is possible any investigation may uncover information that may be of concern as to the identity of the reporter.

False Allegations

No action will be taken against any individual making a report in good faith, even where the allegations are not confirmed by the subsequent investigation.

Non-Retaliation

We aim to encourage openness and will support employees who report genuine concerns under this Policy. 

This Policy is designed to offer protection to those employees who report concerns in good faith, in the reasonable belief that the report tends to show malpractice or impropriety, that the disclosure is made to an appropriate person and in line with this Policy and any related procedures. 

Non-retaliation is one of the core principles under this Policy and we operate a zero-tolerance policy for all forms of retaliatory behaviour against individuals reporting concerns.

What is Whistleblowing?

Whistleblowing

Whistleblowing is the disclosure of information which relates to suspected wrongdoing, breach of law or dangers at work. This may include: any suspected fraudulent conduct, corrupt conduct, bribery, negligence, violation of any applicable antitrust and competition law rules, violation of personal data protection and the Company system security rules, endangerment of an individual’s health and safety, endangerment of the environment, criminal activity, failure to comply with any legal or regulatory obligation, and deliberate concealment of any information pertaining to any of the above. 

We encourage you to speak up! Any genuine concerns related to suspected wrongdoing or negligence affecting any of our activities should be reported under this Policy.  

Scope of this Policy

If you are uncertain whether something is within the scope of this Policy you should seek advice from the Company’s General Counsel acting as the Speak Up Officer Officer, Caroline Kowall, caroline.kowall@mediamonks.com.

Raising a concern

Employees’ concerns are important to the Company and we encourage you to take advantage of this Policy. 

We hope that in many cases you will be able to raise any concerns directly with your manager or your Human Resources department, but you should feel equally comfortable to raise a concern to any of the following:

  • Your direct, or indirect Manager.
  • Human Resources.
  • The General Counsel acting as the Whistleblowing Officer, or
  • Media.Monks Speak Up Platform supported by Convercent.

Reports may be made in writing or orally.

Handling a concern

If your concern can be handled under this Policy, we will initiate an enquiry. 

The following steps will be taken: 

  • We will acknowledge your report within 5 working days.
  • We will arrange a meeting, whether in person or by video/audio conference (as appropriate) with you as soon as possible to discuss your report. 
  • We will carry out an initial assessment to determine the scope of any investigation.
  • We will tell you who is handling the matter and how you can contact him or her.
  • We will say whether further assistance may be requested.
  • We will provide an estimation of how long the investigation will take.
  • We will advise on what to do if you suffer from immediate or subsequent detrimental action, as a result of raising the report. 
  • We will aim to keep you informed of the progress of the investigation and its likely timescale. The timeframes for investigating concerns raised under this Policy are likely to vary depending on the nature and complexity of the case. We expect that in most cases we will be able to conclude the investigation within 12 weeks. We may also appoint an external investigator with relevant experience or subject matter expertise. Please note however, that we may not be able to tell you specific details of the investigation or the precise action that is being taken to resolve the concern under circumstances where it could infringe a duty of confidentiality owed by us to someone else.

You should treat any information you are given about the investigation as confidential, and we will aim to provide feedback to you as the person making the original report within the same 12-week timeframe.

Results

While we cannot always guarantee the outcome you are seeking, we will commit to deal with your concern fairly and in an appropriate way. By using this Policy, you can help us to achieve this.

If you are not happy with the way in which your report has been handled, you can raise this issue with the General Counsel acting as the Whistleblowing Officer, Caroline Kowall, caroline.kowall@mediamonks.com.

Breach of Policy

Where any member of staff breaches this Policy, this will be considered a breach of the Company’s Code of Conduct and dealt with accordingly. Where any member of staff breaches this Policy, this will be considered a breach of the Company’s Code of Conduct and dealt with accordingly.

In limited circumstances, serious breaches or incidents may need to be reported to the appropriate authorities, including any regulatory or enforcement authorities. In such cases, Media.Monks will take reasonable steps to ensure the identify of any reporting employee is confidential, unless disclosure is unavoidable to comply with legislation.

Governance

The Board has overall responsibility for this Policy, and for reviewing the effectiveness of actions taken in response to concerns raised under this Policy. 

All whistleblowing concerns raised formally under this Policy will be reported periodically to the Board, although individual names of reporters will be kept confidential.

This Policy is part of Media.Monks’s Governance Framework which includes: 

  • Code of Conduct.
  • Prevention of Financial Crime Policy.
  • Other Group Policies as approved by the Board of Directors.

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