Whistleblower Policy

Prodia Systems Ltd ("Prodia") encourages and protects the reporting of suspected wrongdoing. This policy implements the Protected Disclosures Act 2014 (as amended by the Protected Disclosures (Amendment) Act 2022) and Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law.

1. Who may report

• Current and former employees, directors, shareholders, contractors, interns, applicants and persons working under the supervision of Prodia.
• Customers, suppliers and members of the public with knowledge of suspected wrongdoing.

2. What may be reported

• Criminal offences, breach of legal obligations, miscarriages of justice.
• Endangerment of health, safety or the environment.
• Breaches of EU law within the material scope of Directive (EU) 2019/1937 (including financial services, product safety, public health, consumer protection, privacy and data protection, network and information security).
• Fraud, bribery, corruption, anti-competitive conduct, and misuse of customer or user data.
• Material misuse of Prodia's autonomous systems, governance circumvention, or falsification of audit evidence.
• Retaliation against any person who has made or is contemplating a protected disclosure.

3. How to report

• Internal channel: whistleblower@prodia.dev — monitored only by a designated disclosures recipient bound by confidentiality.
• Anonymous reports are accepted and investigated to the extent the information permits.
• External channels: prescribed persons under Schedule 2 of the Protected Disclosures Act 2014, the Office of the Protected Disclosures Commissioner, or the appropriate competent authority of an EU Member State.

4. Process and timelines

• Acknowledgement of receipt within 7 days.
• Diligent follow-up by an impartial recipient; feedback to the reporting person within 3 months of acknowledgement.
• Records retained in line with statutory and limitation-period requirements; access restricted on a need-to-know basis.

5. Protection from penalisation

Penalisation of a reporting person for having made, or being suspected of making, a protected disclosure is unlawful and is itself a disciplinary offence under this policy. Protected acts include dismissal, suspension, demotion, transfer, withholding of training, negative performance assessment, coercion, harassment and ostracism.

Knowingly false reports made in bad faith are not protected and may themselves attract disciplinary or legal action.