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Policy

Whistleblower Policy

Stratavor maintains a safe, confidential way to report concerns in good faith with clear channels, strict non-retaliation protections, and a defined investigation process.

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Version: 1 Effective date: December 27, 2025 Review cycle: Annual

1. Purpose

Stratavor is committed to the highest standards of ethics, compliance, and transparency. This policy enables anyone who works with Stratavor, employees, contractors, interns, advisors, and vendors to report suspected wrongdoing or risks safely and, if desired, anonymously.

2. Scope

This policy applies to all Stratavor personnel and third parties working with or on behalf of Stratavor in any country.

3. What to Report

  • Financial misconduct, fraud, bribery, corruption, or kickbacks
  • Breaches of law or policy (e.g., data protection, cybersecurity, human rights)
  • Harassment, discrimination, bullying, retaliation, or conflicts of interest
  • Health & safety risks, environmental harm, or unsafe work practices
  • Manipulation of data, accounting irregularities, or misrepresentation to clients/investors
  • Any attempt to conceal, destroy, or tamper with evidence of the above

4. How to Report

You may use any of the following channels:

  • Dedicated email: privacy@stratavor.com (access restricted to ESG & Compliance Lead)
  • CEO/Founder escalation (if the issue involves the ESG Lead): jgoodwin@stratavor.com
  • Anonymous web form: link to be provided on the internal wiki and contractor onboarding pack
  • Emergency situations: In emergencies or imminent risk of harm, contact local emergency services first.

5. Non-Retaliation and Confidentiality

Retaliation against anyone who raises a concern in good faith is strictly prohibited and will result in disciplinary action, up to and including termination of contract. Stratavor will treat reporter identity and report details as confidential, sharing only with those who need to know to investigate and remediate.

6. Investigation Process and Timelines

  • Acknowledgement: We aim to acknowledge receipt within 5 business days.
  • Triage and Assignment: The ESG & Compliance Lead (or designee) assigns an investigator not implicated in the matter.
  • Fact-Finding: Interviews, document review, and evidence gathering (target completion within 30 calendar days where practical).
  • Outcome and Actions: Findings and corrective actions will be documented; a summary (to the extent legally possible) will be provided to the reporter.
  • Escalation: Serious or criminal matters may be escalated to the Board and/or relevant authorities.

7. Records and Data Protection

Investigation records will be retained securely for at least seven (7) years, or longer where required by law. Personal data will be handled in accordance with Stratavor’s Privacy Notice and applicable data protection laws (e.g., GDPR).

8. External Reporting

Nothing in this policy restricts your right to report concerns directly to competent regulators or law enforcement, or to seek independent legal advice.

9. Roles and Responsibilities

  • ESG & Compliance Lead: Owns this policy, receives and triages concerns, ensures fair investigations, and reports annually to the Board.
  • Managers: Foster a speak-up culture, promptly escalate concerns, and support investigations.
  • All Personnel & Vendors: Raise concerns in good faith and cooperate with investigations.

10. Related Policies

Code of Conduct; Anti-Corruption & Anti-Bribery; Human Rights; Health & Safety; Cyber Security; Customer Privacy Notice; Environmental Policy.