Whistleblower channel

Purpose

SAUCINCO SAS wants people to be able to raise serious concerns early, safely, and in good faith. This policy explains how employees, founders, contractors, suppliers, candidates, clients, and other people connected with Saucinco may report suspected wrongdoing or serious misconduct.

It supports responsible business conduct. It does not replace any legal reporting route, employment procedure, client complaint process, emergency service, or professional advice.

What should be reported

You may use this channel to report a genuine concern about:

• fraud, bribery, corruption, theft, or financial misconduct;
• a serious breach of law, regulation, contract, or Saucinco policy;
• conflicts of interest, undisclosed relationships, or misuse of company authority;
• harassment, discrimination, violence, threats, or other serious workplace misconduct;
• forced labour, human trafficking, child labour, exploitation, or serious human-rights concerns;
• misuse, loss, or unauthorised disclosure of personal, client, or confidential information;
• serious information-security, testing-authorisation, or data-protection concerns;
• retaliation against someone who raises a genuine concern; or
• conduct that could seriously harm people, clients, the public, or Saucinco’s integrity.

What this channel is not for

It is not for ordinary service enquiries, routine project disagreements, commercial negotiations, general feedback, or employment requests that belong on another route. If a concern involves both an ordinary issue and serious misconduct, use your judgement and report it.

How to report

Reports may be anonymous. If you identify yourself, please give a safe way to contact you.

A useful report normally explains what happened, when and where, who may be involved, why it is a concern, and what supporting information exists. Do not put yourself or anyone else at risk to obtain evidence, and do not send passwords, unrestricted client data, or unnecessary sensitive information.

What happens after a report

Saucinco aims to acknowledge identified reports within five business days. That is an internal service target, not a guarantee and not a statutory deadline.

1. Receipt and protection. Where a safe contact method is available, Saucinco acknowledges receipt and considers any immediate safety, security, privacy, or evidence-preservation needs.
2. Initial assessment. Saucinco assesses whether the report falls within this policy, whether urgent escalation is needed, and who can review it impartially.
3. Review or investigation. Saucinco may review relevant documents, interview appropriate people, seek professional advice, or appoint an independent reviewer. The scope depends on the seriousness and reliability of the information.
4. Outcome and action. Where a concern is substantiated or indicates a material risk, Saucinco takes proportionate corrective, protective, contractual, disciplinary, or external-reporting action.
5. Feedback. Where the reporter has given a safe contact route and it is lawful and appropriate, Saucinco provides a general update. Confidentiality, privacy, legal privilege, and the integrity of the review may limit the detail that can be shared.

Confidentiality and anonymity

Saucinco handles reports and identities confidentially as far as reasonably possible. Information is shared only with people who need it to assess, investigate, obtain advice, act, or comply with a legal obligation.

Anonymous reporting is accepted, but anonymity may limit Saucinco’s ability to ask follow-up questions, test evidence, or give feedback. Absolute anonymity or confidentiality cannot be guaranteed where disclosure is required by law, necessary to protect someone from serious harm, or needed for a fair legal or investigative process.

Personal data in a report is processed in accordance with the Privacy Notice, under appropriate access and retention controls.

Protection from retaliation

Saucinco will not tolerate retaliation against a person who raises a genuine concern, supports a review, or refuses to take part in wrongdoing. Retaliation includes threats, harassment, discrimination, adverse treatment, or attempts to damage someone’s work or professional position because they made or supported a good-faith report.

You do not lose that protection merely because a concern turns out not to be substantiated, provided it was raised honestly and without knowingly providing materially false information. Knowingly false, malicious, or deliberately abusive reports may be addressed separately.

Conflicts of interest

A report must not be reviewed by anyone named in it, directly involved in it, or otherwise conflicted. Saucinco has two founders: if a report concerns one founder or the normal reporting contact, it goes to the other founder, or to an independent external adviser where that is appropriate.

Who monitors the mailbox, who acts as the alternate reviewer, and how an external adviser is engaged must all be documented before this policy is published.

External reporting and emergencies

Nothing here prevents anyone from contacting a competent public authority, law-enforcement agency, regulator, emergency service, or professional adviser. Saucinco cooperates with lawful investigations.

If there is an immediate threat to life, safety, or security, contact the relevant emergency service or public authority first rather than waiting for an email reply.

Records and retention

Saucinco keeps restricted records of reports, assessments, actions, and outcomes only for as long as reasonably necessary for the review, legal obligations, accountability, dispute management, or protection of rights. Access is limited and the retention period is set in the internal records schedule.

Changes to this policy

Saucinco updates this policy when its business, workforce, suppliers, reporting channels, or legal obligations change. The current version is posted here with a revised date.