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Whistleblower Protection Policy

Effective Date: 23/05/2025 Issued by: Clinicians Check Limited

CliniciansCheck believes in protecting the voices that protect integrity. Whistleblowing is not disloyalty — it is leadership in its highest form.

1. Purpose

CliniciansCheck is committed to maintaining the highest standards of integrity, accountability, and transparency. This policy provides a clear framework for reporting serious concerns (whistleblowing) without fear of retaliation. It applies to all stakeholders including employees, contractors, clinicians, partners, and suppliers.

2. Scope

This policy applies to disclosures related to:

  • Fraud, bribery, or corruption

  • Breaches of data protection, privacy, or confidentiality

  • Unsafe clinical practices or malpractice

  • Modern slavery, exploitation, or human rights abuses

  • Misuse of public or company funds

  • Environmental harm

  • Criminal offences or regulatory violations

  • Attempts to cover up any of the above

Personal grievances (e.g. bullying or harassment) should be handled through HR or appropriate conduct channels, not under this policy unless they involve systemic wrongdoing.

3. Reporting Channels

Reports can be made via:

operationsteam@clinicianscheck.com (confidential inbox)

In writing to: Whistleblower Officer Clinicians Check Limited

2 Harley Street, London, UK

Anonymous reports are permitted, but may limit our ability to investigate fully.

4. Protections for Whistleblowers

CliniciansCheck will:

  • Treat all disclosures seriously and investigate impartially

  • Protect whistleblowers from retaliation, victimisation, or dismissal

  • Maintain confidentiality wherever possible

  • Not tolerate any attempt to interfere with, delay, or suppress a legitimate report

5. Investigation Process

  1. Acknowledgement: Receipt of report within 5 business days

  2. Review: Preliminary review within 10 business days

  3. Investigation: Conducted by the Whistleblower Officer or external advisor if appropriate

  4. Outcome: Shared (where possible) with the whistleblower, including actions taken

All investigations are conducted with discretion, fairness, and due process.

6. False Reporting

Malicious or knowingly false reports are taken seriously and may result in disciplinary or legal action. However, no action will be taken against anyone making a report in good faith, even if the concern is not upheld.

7. Legal and Global Alignment

This policy aligns with:

  • UK Public Interest Disclosure Act 1998 (PIDA)

  • EU Whistleblower Directive (Directive (EU) 2019/1937)

Global good practice frameworks including ESG and NHS DSP Toolkit governance

8. Monitoring and Review

This policy will be reviewed annually. Learnings from disclosures (where appropriate) will be used to improve governance and safety across the platform.

9. Contact

For questions about this policy or confidential guidance, contact:

operationsteam@clinicianscheck.com

10. Retaliation Safeguard Expansion

No individual who raises a concern in good faith will suffer harassment, retaliation, or adverse employment or commercial consequence. This includes protection from demotion, termination, exclusion from opportunities, or defamation.

11. Independent Escalation Pathway

If you believe your report has not been handled appropriately by internal teams, you may escalate to an independent advisor or designated compliance officer. External ombudsman referral may also be available depending on your jurisdiction.

12. Jurisdiction and Enforcement

This policy shall be governed by the laws of England and Wales, without prejudice to stronger whistleblower protections available under the laws of the EU, United States (e.g., Sarbanes-Oxley, Dodd-Frank), Australia, or your country of residence. CliniciansCheck is committed to upholding the strongest applicable standard globally.