Policies & Legals

1. Introduction

SkootEco is committed to trading ethically and honestly, supporting employees, associates, contractors and consultants in reporting any fraud, misconduct or wrongdoing of others or the way in which the business is run. This policy sets out the way in which individuals may raise concerns and how those concerns will be dealt with. SkootEco promotes an environment of trust, which is open, safe and secure and believes that good communications at all levels promote better business practice. We recognise the negative effect which malpractice or wrongdoing can have on the organisation, and, therefore, encourages all genuine concerns, alleged or suspected malpractice or wrongdoing are raised without fear of reprisals.

2. Background

This policy has been developed in accordance with the Public Interest Disclosure Act (1998) and amended the employment rights act 1996, which provides protection for employee’s, associates, contractors and consultants to raise legitimate concerns. These are called ‘Qualifying disclosures’. A qualifying disclosure is made in good faith following reasonable belief that;

• A criminal offence has been committed
• Failing to comply with a legal obligation
• A miscarriage of justice
• An act creating risk to health and safety
• An act causing damage to the environment
• Concealment of any of the above

3. Scope

This policy applies to all employees, associates, contractors and consultants of SkootEco.

4. Principles

Everyone should be aware of the importance of preventing and eliminating wrongdoing in the workplace by reporting any unethical conduct. Any matter raised under this procedure will be investigated thoroughly, promptly and confidentially, and the outcome of the investigation reported back to the individual who raised the issue. Concealment or lack of reporting any wrongdoing or victimisation towards any Individual raising concerns will be dealt with under the disciplinary procedures. The company reserves the right to invoke the disciplinary procedures for any malicious or false allegations made with the intent of causing harm. Any result of a disciplinary hearing where malicious or false allegations are made, may result in dismissal. Anyone raising concerns will be supported under this policy. This means that employment will continue without any detriment to future promotion or training opportunities.

5. Internal Procedure

In order to raise a concern, you must immediately highlight your concerns to your line manager, preferably in writing. Your concerns will then be discussed with the senior management. If you are unable to initially raise your concerns to your line manager you should follow the chain of command. When reporting a concern, individuals should provide as much information and detail as possible, including name and contact details. In particular the names of the people involved.

6. Initial meeting

An initial meeting will be arranged with you as soon as possible to discuss your concern. This will be arranged within the receipt of 7 days of your complaint. You may bring a colleague or union representative to any meetings. Your companion must respect the confidentiality of your disclosure and any subsequent investigation. Should be removed. During the meeting a written summary of your concern will be taken and a copy provided to you. We will also aim to give you an indication of how we propose to deal with the matter.

7. Investigation

A manager will be appointed to investigate the concerns raised. The investigation will be concluded as quickly as possible, ensuring a thorough investigation throughout. Once the investigating manager has concluded the investigation and assuming the concern was not raised anonymously, we will look to advise you of the findings, the outcome of the investigation and what action has been taken. If no action is to be taken, the reason for this will be explained. The provision of providing detail of findings and outcome is subject to legally binding obligations of confidentiality and restrictions imposed by SkootEco.

8. Appeal

If you are not satisfied with the investigation and/or outcome you may write the details of dissatisfaction to your line manager or if this is not possible, follow the chain of command. A response will be sent within 7 days to confirm further investigation or rejection and reasons for this.

9. External Procedure

SkootEco strongly encourages the compliance of internal procedure, however, If you believe that appropriate action has not been taken following your compliance of the internal procedure, you should report the matter to the proper authority. You may also wish to highlight to authorities for the following reasons;

• If the concern is exceptionally serious,
• If following the internal procedure may result in detriment
• If you feel the evidence will be concealed or destroyed by following the

internal procedure The legislation sets out a number of bodies of which qualifying disclosures may be made. These include:

• HM Revenue and Customs
• The financial services authority
• The office of fair trading
• The offices of Communications (OFCOM)
• Financial conduct authority (FCA)
• Office of fair trading
• Health and safety executive
• The environment agency
• The Comptroller and auditor general
• The Director of the serious fraud office
• Payments systems regulator
• Competition and markets authority
• The information commissioner
• The Pensions regulator
• Public concern at work

10. Protection

SkootEco discourage fear of reprisal and promotes transparency when putting your name to any disclosure made to assist with investigations and providing outcomes. You must not suffer any detrimental treatment as a result of raising a concern. Should you be subjected to any such treatment, threats, bullying, harassment, you must follow the grievance procedures. If any detrimental treatment is found, disciplinary action will be taken, which may result in dismissal. In some case’s the whistle blower could have the right to sue anyone personally for compensation as a result of detrimental treatment. Anonymous disclosures will be considered at the company discretion. We do not encourage anonymous disclosures as it makes investigation more difficult or impossible if we need to obtain further information. If it is necessary for anyone investigating your concern to know your identity, we will discuss this with you. If you have concerns about raising a concern you can seek advice from the public concern at work, the independent whistleblowing charity, who offer a confidential helpline. Disciplinary action will also be taken against anyone who makes malicious or false allegations or tries to prevent or deter any genuine disclosure from being made.

11. Responsibilities

All mentioned within the scope of this policy have a responsibility to adhere to and ensure the ethical practice of SkootEco. We also welcome you to comment on this policy and suggest ways in which it might be improved. Management should encourage the application of this policy. The operations team should ensure the policy is applied and maintain regular review and updating of the policy.

Contact Details

If at any time you would like to contact us with your views about our privacy practices, or with any enquiry relating to your Personal Data, please use one of the following means:

• By email:

[email protected]

• By mail or courier to:

Attn: Privacy Officer
SkootEco Group Ltd.
86-90 Paul Street, 3rd Floor
London, England
EC2A 4NE