Whistleblower Protection Policy

For clarity this policy refers to Gemserv Limited, trading as Talan.

1. Purpose

Gemserv Limited, trading as Talan are committed to fostering an ethical workplace. This policy protects individuals who report misconduct, ensuring they can do so without fear of retaliation.

2. Scope

This policy applies to all employees, contractors, suppliers, and stakeholders who report concerns related to:

• Fraud, corruption, or financial misconduct.
• Violations of laws, regulations, or company policies.
• Environmental or health and safety risks.
• Harassment, discrimination, or unethical behaviour.

3. Reporting a Concern

Concerns can be reported through any of the following confidential channels:

• Email: [add email]
• Whistleblower Form:
  • Word Version of Form
  • PDF Version of Form
  • Online form below
• Mail: FAO: Head of Governance, Risk & Compliance (GRC), Talan, 77 Gracechurch Street, London, EC3V 0AS

Reports may be submitted anonymously; however, including contact details allows for follow-up and better resolution.

4. Investigation & Resolution

• An impartial investigation will be conducted.
• Findings and corrective actions will be communicated where possible, while maintaining confidentiality.

5. Protection from Retaliation

Gemserv Limited, trading as Talan strictly prohibits retaliation against anyone who raises a concern in good faith. This includes:

• Dismissal or demotion
• Harassment or victimisation
• Supplier contract termination
• Blacklisting or damaging reputation

If a whistleblower believes they are experiencing retaliation, they may escalate directly to:

• Head of Governance, Risk & Compliance – [add email]
• Or request escalation to a senior executive outside the direct reporting line.

Whistleblower protection applies equally to external individuals, including employees of suppliers, clients, and partners.

6. Confidentiality & Support

All concerns will be handled confidentially. Gemserv Limited, trading as Talan will protect the identity of the whistleblower wherever possible. Anonymous concerns will be considered if sufficient detail is provided to support a fair investigation. For further guidance, employees and stakeholders are encouraged to contact Gemserv Limited, trading as Talan's GRC team.

7. What is not Covered

The whistleblowing policy does not cover:

• Customer service complaints (use the public grievance process)
• Employment grievances (handled under internal HR grievance procedures)
• Issues already under litigation or external investigation

8 Enforcement and Consequences

Any individual found to have retaliated against a whistleblower or obstructed an investigation will be subject to disciplinary action, which may include termination of employment or contracts, and legal action.

9 Oversight and Review

The policy is reviewed annually by the Governance, Risk & Compliance function and approved by senior management.