1. Purpose
Gemserv Ltd is 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: grc@gemserv.com
- Whistleblower Form:
- Mail: FAO: Head of Governance, Risk & Compliance (GRC), Gemserv Ltd, 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 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 – grc@gemserv.com
- 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 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’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.