Whistleblowing Policy

Purpose of this policy

Environmental certificate markets depend on trust.
Trust depends on people speaking up when something isn’t right.

This policy protects anyone — employee, contractor, counterparty, or third party — who raises a genuine concern about wrongdoing connected to our business.

It explains what you can report, how you can report it, how we protect you, and what happens next.

1. What you can report

You can report anything that looks like:

Misconduct

  • bribery
  • corruption
  • money laundering
  • fraud
  • market manipulation
  • double counting or double claiming of certificates
  • falsification of sustainability data
  • misuse of registry access
  • conflicts of interest being hidden
  • suspicious or irregular trading activity

Legal or regulatory breaches

  • violations of market rules
  • sanctions breaches
  • AML concerns
  • environmental reporting fraud
  • unsafe work practices

Unethical behaviour

  • pressure to bypass controls
  • unusual incentives
  • retaliation against staff
  • intimidation
  • attempts to conceal problems
  • behaviour that undermines market integrity

If something feels wrong, report it — even if you’re not certain.

2. Who can raise a concern

Anyone connected to our business, including:

  • employees
  • contractors
  • consultants
  • introducers or TPIs
  • certificate buyers
  • certificate sellers
  • suppliers
  • registry partners
  • anyone who observes suspicious activity relating to us

You do not need evidence.
A reasonable suspicion is enough.

3. How to report a concern

You can report in any of the following ways:

Email (direct):

compliance@energymarketingandtrading.com

Anonymous reporting platform:

[secure, untraceable reporting link]

Phone:

0131 610 8868

Report to a senior manager:

If speaking to someone directly feels safer.

You can choose the channel that feels most comfortable.
All reports are treated with the same seriousness.

4. Confidentiality

We treat whistleblowing reports with:

  • strict confidentiality
  • restricted visibility (only those investigating)
  • secure record-keeping
  • careful redaction where appropriate

Your identity will be protected unless disclosure is legally required.

Even then, we will inform you first.

5. Protection from retaliation

We guarantee:

  • no dismissal
  • no demotion
  • no threats
  • no harassment
  • no discrimination
  • no negative impact on your role or relationship with us

Retaliation against a whistleblower is a disciplinary offence and may lead to termination of employment or commercial relationships.

We would rather lose a member of staff or a counterparty than allow retaliation to take root.

6. How we handle reports

When you raise a concern:

  1. We acknowledge receipt (unless anonymous).
  2. We conduct an initial risk assessment.
  3. If required, we open a formal investigation.
  4. We may request additional information — confidentially.
  5. We gather evidence (documents, logs, communications, registry records).
  6. We take action, which may include:
    • pausing trading
    • suspending access
    • enhanced monitoring
    • notifying authorities
    • terminating relationships
  7. We close the case and record the outcome.

If you disclosed your identity, we will update you on progress where possible.

7. When whistleblowing is NOT the right route

Issues related to:

  • personal employment disputes
  • performance reviews
  • interpersonal conflicts
  • HR matters unrelated to wrongdoing

…should be handled through normal HR or management channels.
This policy is for wrongdoing, not disagreements.

8. Acting in good faith

We do not require proof — only honesty.

You are protected if you report:

  • in good faith
  • based on reasonable belief
  • even if the concern ultimately turns out to be mistaken

Malicious or knowingly false reports are a disciplinary offence.

9. Our commitment to a speak-up culture

We actively encourage reporting because:

  • small issues become big issues when ignored
  • internal transparency builds external trust
  • it protects our counterparties and clients
  • it strengthens the market

Speaking up is not disloyal.
It is an essential part of market integrity.

10. Why this matters

Environmental certificates only hold value if markets stay clean.

Whistleblowing:

  • exposes misconduct early
  • prevents fraud
  • protects counterparties
  • strengthens compliance
  • builds a culture of integrity
  • protects the credibility of REGOs, RGGOs, GOs, I-RECs, and all the instruments we trade

Your voice protects the entire market.

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