Global Whistleblowing Policy

A whistleblower is anyone who has and reports insider knowledge of illegal activities occurring in an organisation. Whistleblowers can be employees, suppliers, contractors, clients, or any individual who becomes aware of illegal past or present work related activities. Whistleblowers are protected from retaliation under various regulations. Whistleblower protection refers to the reporting of wrongdoing related to the law.

The goals of the this Policy are:

• To detect and prevent misconduct and breaches of laws and regulations,
• To improve law enforcement by establishing effective, confidential and secure reporting channels to effectively protect whistleblowers from fear of retaliation,
• To protect and enable whistleblowers by helping them to raise concerns confidently without fear of retaliation, by ensuring anonymity.

Whistleblowers are vital for maintaining an open and transparent business, as they expose misconduct or hidden threats. By ensuring that effective whistleblowing arrangements are in place, employees and other stakeholders are encouraged to raise concerns internally. By doing so, Remote has an opportunity to identify and manage risk at an early stage, helping to avoid or limit financial and reputational damage.

The core feature of this Policy is protection of whistleblowers.

Protection applies to individuals working at Remote who acquire information on suspected breaches in a work-related context. This includes current and former:

• employees – this includes any individual who performs services for and under the direction of another person, in return for remuneration. Protection covers employees in non-standard employment relationships, including fixed-term workers, agency workers and other atypical relationships,
• self-employed individuals, including freelance workers, contractors and subcontractors,
• shareholders,
• members of an administrative, management or supervisory body,
• volunteers,
• trainees (paid or unpaid),
• those working under the supervision/direction of contractors, sub-contractors and suppliers,
• new recruits who have not yet commenced work,
• facilitators (someone who assists a person in the reporting process in a work-related con­text),
• third persons connected with a reporting person who could suffer work-related retaliation (eg colleagues or relatives),
• legal entities that the reporting person is connected to in a work-related context,
• job applicants,
• former employees,
• supporters of the whistleblower.

These persons are legally protected from dismissal, degradation and other forms of retaliation. Retaliation is defined broadly and includes:

• suspension, lay-off, dismissal or equivalent measures
• demotion or withholding of promotion
• transfer of duties, change of location of place of work, reduction in wages or change in working hours
• withholding of training
• a negative performance assessment or employment reference
• imposition or administering of any disciplinary measure, reprimand or other penalty, including a financial penalty
• coercion, intimidation, harassment or ostracism
• discrimination, disadvantageous or unfair treatment
• failure to convert a temporary employment contract into a permanent one, where the worker had legitimate expectations that they would be offered permanent employment
• failure to renew, or early termination of, a temporary employment contract
• harm, including to the person's reputation, particularly in social media, or financial loss, including loss of business and loss of income
• blacklisting on the basis of a sector or industry-wide informal or formal agreement, which may entail that the person will not, in the future, find employment in the sector or industry
• early termination or cancellation of a contract for goods or services
• cancellation of a license or permit
• psychiatric or medical referrals

To ensure retaliation does not occur, all Remoters are provided with training.

Protection applies to reports of wrongdoing related to (the Scope):

• suspected/known criminal offence/-s
• suspected/known administrative offence/-s
• public procurement
• financial services, products and markets, and prevention of money laundering and terrorist financing
• product safety and compliance
• transport safety
• protection of the environment
• radiation protection and nuclear safety
• food and feed safety, animal health and welfare
• public health
• consumer protection
• protection of privacy and personal data, and security of network and information systems
• breaches affecting the financial interests of the state/country
• breaches relating to the European internal market

How you can submit the report:

The whistleblower can submit an internal report either in writing via a secure mailbox: whistleblowing@remote.com. You can choose to submit the report from an anonymous email address without providing your name or any other identification data.

You can use our online Whistleblower Reporting form to submit the report (the report is anonymous, you do not need to provide us with your name, email address nor phone number).

You can choose to submit your report via a private telephone call/private zoom call/other private communication apps call (with a Compliance Officer or another member of the Compliance Team). To schedule a call please write an email with this request to: whistleblowing@remote.com. If you choose to have a call, you can still remain anonymous.

Your report will be handled by an impartial and experienced person or persons from the Compliance Team (Designated Department under the Directive).

If a Compliance Team member wishes to submit a report, it may be sent by the above mentioned channels or by an email (anonymously or non-anonymously) to the Remote’s Chief People Officer.

If nothing happens in response to an internal report, or if the whistleblower has reason to believe that it is in the public interest, the whistleblower can submit a report to the competent authority in the country of their residence or also go directly to the public. Protection of the reporter applies in all cases.

If:

1. Your case, concern, or information pertains to any area beyond the Scope, please direct your email to help@remote.com; OR
2. You are or were an employee or contractor at Remote, and your case involves your individual employment situation, kindly send an email to help@remote.com or utilise the anonymous feedback feature available in the Share my feedback section within your Remote account platform.

Every report will receive a response, regardless of the chosen communication channel's suitability therefore if you are not sure which channel to choose, please do not hesitate to send an email to whistleblowing@remote.com first.

Whistleblower protection applies when:

• the whistleblower reports internally (within their employer’s organisation) or externally (to a competent authority) or make a public disclosure (place information in the public domain); and
• the whistleblower has reasonable grounds to believe, given the circumstances and the information available to them at the time of reporting, that the matters they report are true, and that the information reported fell within the scope of the Policy. The protection is not lost when someone reports inaccurate information because of an honest mistake. The motives of the whistleblower are irrelevant in deciding whether they should receive protection.

An individual who makes an anonymous report is protected if they are subsequently identified and suffer retaliation.

Anonymity and information security

For all reporting channels, the identity of the whistleblower is strictly protected. All data is handled in accordance with the data protection regulations.

What happens after a report is filed?

After the report is submitted, the reporter will receive an acknowledgement receipt of the report not later than seven days. All reports are documented, and follow up measures are taken and monitored, each report is handled with confidentiality and next steps are taken with consideration of anonymity of the reporter. Records of every report are kept, but for no longer than is necessary and proportionate to comply with the legal requirements.

As much as practically possible, the reporter may be involved in the case solving, if such will is expressed. Within three months, the reporter receives a follow up on the case and/or feedback.

Different jurisdictions:

Different jurisdiction approach the issue of whistleblowing in different ways, adopting different legislation in this area. Remote endeavours to take different regulations in consideration, to embrace them by this Policy and to guarantee to the reporters with all rights according to the jurisdiction of their residence. Below you can find information specific to certain jurisdictions covered by this Policy.

United States residents

Please read this notice if you are an employee residing in California

This Policy fulfils provision of the following federal acts:

• Anti-Money Laundering Act;
• Consumer Financial Protection Act;
• Criminal Antitrust Anti-Retaliation Act;
• SOX;
• Taxpayer First Act;
• section 11(c) of the Occupational Safety and Health Act (OSH Act);
• Asbestos Hazard Emergency Response Act;
• Clean Air Act;
• Comprehensive Environmental Response, Compensation and Liability;
• Energy Reorganisation Act;
• Federal Water Pollution Control Act;
• Safe Drinking Water Act
• Solid Waste Disposal Act;
• Toxic Substances Control Act;
• Consumer Product Safety Improvement Act;
• FDA Food Safety Modernisation Act;
• Moving Ahead for Progress in the 21st Century Act;
• Federal Railroad Safety Act;
• International Safe Container Act;
• National Transit Systems Security Act;
• Pipeline Safety Improvement Act;
• Seaman’s Protection Act;
• Surface Transportation Assistance Act;
• Wendell H Ford Aviation Investment and Reform Act for the 21st Century;
• Affordable Care Act.

If any other act of federal or state law grants any other rights to the reporters, Remote undertakes to respect these rights in the widest possible if this is practically possible.

United Kingdom residents

This Policy fulfils the provisions of the Employment Rights Act 1996 (as amended by the Public Interest Disclosure Act 1998 and the Employment and Regulatory Reform Act 2013) set out for the whistleblowing frameworks. All the rights stipulated by the Employment Rights Act 1996 for the reporters are guaranteed under this Policy.

European Union member-states residents

This Policy is an execution of the DIRECTIVE (EU) 2019/1937 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 23 October 2019 on the protection of persons who report breaches of Union law (hereinafter referred to as ‘the Directive’) and underlying transposition regulations in member states. If the law of a member-state grants more rights to the reporter than this Policy, Remote undertakes to respect these rights.

As indicated in Article 9 paragraph 1 point (g), below you can find the information about member-states and their competent authorities where you can submit an external whistleblower report:

If your report concerns the financial services provided by Remote Payment Services (RPS), or relates to RPS’s activities, you may submit it directly to the relevant authority: