Speak Up (Whistleblowing) Policy
This Speak Up Policy applies to Uncountable Inc. and its subsidiaries (together, “Uncountable”, “we”, “our” or “us”). It explains how to raise a concern about wrongdoing connected to our business, how we handle it, and how we protect people who speak up.
1. Who this policy covers
This policy is for anyone outside Uncountable who has a concern about our business, including customers, partners, and other third parties.Where local law gives greater protection, local law applies.
2. What you can report
Report any concern you reasonably believe shows wrongdoing connected to Uncountable, for example:
• Fraud, bribery, corruption, or financial misreporting
• Breaches of law or regulation, including export controls, sanctions, and competition law
• Data protection or information security breaches
• Risks to health, safety, or the environment
• Product quality issues being concealed or misrepresented to customers
• Discrimination, harassment, or modern slavery
• Retaliation against someone who raised a concern
• Any attempt to cover up the aboveYou don't need proof, only a reasonable belief.
3. How to report a concern
Email quality@uncountable.com, or raise the concern with your usual Uncountable contact.
All reports are received by Uncountable's Quality & Compliance team, a small group of senior leaders. Anyone named in or involved with a concern is excluded from handling it.
If you raise a concern with your Uncountable contact, they will pass it to the Quality & Compliance team and keep it confidential.
Include as much detail as you can: what happened, when, where, who was involved, and any documents or evidence.
4. Confidentiality
Reports are confidential, not anonymous. We share a reporter's identity only with people who need it to investigate, or where the law requires it, and we will tell you first where we can. We also protect the identity of anyone named in a report.
5. Protection from retaliation
Uncountable will not tolerate retaliation against anyone who raises a concern in good faith or helps an investigation, even if the concern turns out to be mistaken. Retaliation includes dismissal, demotion, loss of work or business, harassment, or threats.
Anyone who retaliates will face disciplinary action, up to and including dismissal or ending a business relationship. If you believe you've been retaliated against, report it through any channel in section 3.
Knowingly making a false report is a breach of this policy and may lead to disciplinary action.
6. What happens after you report
1. Acknowledgment within 7 days for reports where we can reach you.
2. Assessment. The Quality & Compliance team reviews the concern and decides how to investigate. Anyone with a conflict of interest is excluded.
3. Investigation. We may involve outside counsel or advisers where needed.
4. Feedback within 3 months of acknowledgment, telling you what action was taken or planned, as far as confidentiality and the law allow.
5. Records. We keep a confidential log of each report, the steps taken, and the outcome, with access limited to those handling it. Records are kept only as long as needed and in line with data protection law.
7. Reporting outside Uncountable
We encourage you to report internally first so we can act quickly, but nothing in this policy stops you from reporting to a government authority or regulator, or requires you to tell Uncountable that you have.
US: Government agencies such as the SEC, OSHA, EEOC, Department of Labor, or NLRB, and state agencies
UK: A "prescribed person" under the Public Interest Disclosure Act, such as HMRC, the HSE, or the ICO. The charity Protect offers free confidential advice
Germany: The federal external reporting office at the Bundesamt für Justiz, or BaFin or the Bundeskartellamt where relevant, under the Hinweisgeberschutzgesetz
Other countries: The relevant local authority under local law
US trade secret notice: under the Defend Trade Secrets Act, you will not be held liable for disclosing a trade secret in confidence to a government official or attorney solely to report or investigate a suspected violation of law, or in a sealed court filing.
