S.AI.L's Whistleblowing Policy
Our commitment
S.AI.L maintains the highest standards of professional integrity as an AI solutions and innovation studio. We are committed to ethics, accountability, responsible AI, legal and regulatory compliance in everything we do. This commitment strengthens our ability to serve clients as trusted advisors
Why this policy matters
As humans working with advanced AI technologies, we understand that ethics and responsible AI challenges can be complex and nuanced. This policy recognises that speaking up about wrongdoing demonstrates your commitment to our shared values
We protect those who uphold our standards and report concerns in good faith. What matters is how you respond when you see something that concerns you. This policy creates a safe space for you to raise concerns without fear of retaliation
Who this policy covers and where wrongdoing can happen
This policy applies to everyone who works with S.AI.L: team members, leadership, contractors, consultants, business partners, and suppliers
You might witness wrongdoing whilst representing S.AI.L professionally at sites that are external to your usual place of work. Report it regardless of where it happens
Your commitment to integrity matters. We investigate all concerns about wrongdoing wherever they occur and whoever is involved
You may report wrongdoing that affects others. Respect the victim's wishes regarding how to proceed. Ask for their consent before filing a report on their behalf
What constitutes wrongdoing
Wrongdoing means conduct that violates the law, our policies, or ethical standards. It includes actions that could harm S.AI.L, our clients, our team members, or the public. You do not need to be certain that wrongdoing has occurred. You need only have reasonable grounds to believe it has happened or may happen
5. Primary reporting channel: Whistlelink
We use Whistlelink, an independent third-party service, for all whistleblowing reports. This ensures professional handling and protects your confidentiality
How to access Whistlelink
Visit https://sail.whistlelink.com. If you are a S.AI.L team member, you do not need to log in to S.AI.L's internal systems to access Whistlelink
Reporting options
Anonymous: Your identity remains completely unknown to S.AI.L. We cannot contact you for additional information
Confidential: We know your identity but keep it confidential. You agree that we may contact you to ask further questions. It is your choice whether to respond to our questions or not. We will never disclose your name to colleagues or people who are unconnected to a preliminary assessment or an investigation. We will never disclose your identity without your explicit written consent, except where required by law
Reporting concerns
If you have been the victim of a criminal act or if someone's life is in danger, contact law enforcement authorities immediately
Our Whistlelink portal accepts reports about all forms of suspected wrongdoing, including:
Bribery and corruption
Breaches of S.AI.L's Code of Conduct
Breaches of S.AI.L's Responsible AI Policy
Bullying and harassment
Cybercrime
Discrimination
Environmental violations
Fraud and financial misconduct
Handling of personal data
Health and safety violations
Misuse of company assets
Procurement irregularities
For employment grievances
While employment matters like pay disputes or performance issues are typically handled through HR channels and in accordance with S.AI.L's grievance policy. You can report these through Whistlelink. We will route employment grievances to our HR team
If you are unable to access Whistlelink
If you cannot access Whistlelink or if technical issues are preventing you from filing a report, please use one of the following routes to request technical support:
Send an email to support@whistlelink.com
We do not recommend that you use your S.AI.L email address to contact Whistlelink. Do not include any information or personal data from specific whistleblowing cases. In the event such information is included, Whistlelink will immediately delete your support request
AI assistance for report preparation
Avoid using S.AI.L's Microsoft 365 Copilot for preparing whistleblowing reports
Copilot interactions are comprehensively logged in our audit systems and may be accessible to compliance investigators, potentially compromising your confidentiality
Other sources of AI assistance
Use personal devices with personal AI accounts. You may wish to verify that your preferred AI tool offers you the option to submit private prompts
Recording conversations and gathering evidence
Do not record conversations to gather evidence
Recording workplace conversations without consent may constitute misconduct and create legal risks under data protection laws
Instead:
Take contemporaneous notes during or immediately after incidents
Identify potential witnesses who can corroborate your concerns
Report promptly while memories are fresh
Trust our investigation process to gather necessary evidence
Our investigators can access necessary metadata through proper channels without requiring you to secretly record conversations
Microsoft Teams calls on our enterprise account generate metadata showing participants, times, and duration. Chat logs and shared documents are available through our compliance systems
Protection against retaliation
S.AI.L prohibits retaliation against anyone who reports suspected wrongdoing in good faith. Retaliation includes:
Threats of dismissal, demotion, or suspension
Harassment, intimidation, or other threats
Discrimination in work assignments or opportunities
Any other adverse treatment related to your report
If you experience retaliation, report it immediately through Whistlelink or to compliance@sail.legal. We will investigate and take appropriate action
Investigation process
Acknowledgment
We acknowledge receipt of all reports within 48 hours
A member of staff will be assigned to act as your interface with the investigation team. They will not be part of the investigation team. Their role will be to answer any questions you have about the investigation process
Initial assessment
The investigation team will conduct a preliminary review to determine the appropriate investigation approach
Investigation
We investigate thoroughly, fairly, and confidentially. Investigations typically conclude within 30 days, though complex matters may require additional time
Communication
During the investigation process, the investigation team may ask your support representative to ask you to provide additional information
You do not need to provide additional information. If you choose not to provide additional information, the investigation team will continue to investigate your concerns using the information you supplied to us within your report
Resolution
It is important to note that the investigators are not responsible for assessing guilt or passing judgment. The investigation team may make directions for corrective action to be taken
This will may include policy changes, process amendments, disciplinary action against alleged perpetrators and other outcomes. Your support representative will communicate the investigation team's conclusions to you but this might not include disclosure of their recommendations
The investigation team will provide their directions to the CEO. The CEO will be responsible for implementing directions. Your name and the names of witnesses will not be disclosed to the CEO
Good faith reporting
We protect reports made in good faith, even if the investigation does not substantiate the concerns raised. Good faith means you genuinely believe the information you are providing is true and accurate
We do not protect reports that are knowingly false, malicious, or made for personal gain. Making false reports may result in disciplinary action
Support and resourcing
Reporting wrongdoing can be stressful. If an investigation commences, we are committed to supporting employees who filed reports throughout the investigation process
Contact your support representative if you require additional support or have questions about this policy
If you are an employee and filed an anonymous report and require support such as mental health assistance, or counselling, please reach out to our employee assistance programme or your trades union. Your family doctor may be able to refer you for counselling
If you are not an employee, please reach out to your local trades union or your family doctor
Regular review and updates
We review this policy annually to ensure it remains effective and compliant with applicable laws and regulations. We welcome feedback on how we can improve our approach to handling concerns
Contact information
Primary reporting channel: https://sail.whistlelink.com
Policy questions and suggestions: compliance@sail.legal