Speak Up Policy

DFA Machine is committed to operating with the highest standards of integrity. This policy provides a clear, confidential channel for employees, contractors, suppliers, customers and other stakeholders to raise concerns about suspected wrongdoing, free from fear of retaliation. It implements the UK Public Interest Disclosure Act 1998 and the EU Whistleblowing Directive (2019/1937).

• Breach of law or regulation (fraud, bribery, money laundering, sanctions, competition law).
• Breach of our Code of Conduct, Supplier Code or other policies.
• Health, safety or environmental hazards.
• Modern slavery, human trafficking, harassment or discrimination.
• Information-security or data-protection failings.
• Misuse of company funds, property or information.
• Any deliberate concealment of any of the above.

This channel is for concerns of public interest. Personal grievances should be raised via HR / People processes.

• Line manager: the simplest route for many concerns.
• Compliance team: contact@dfamachine.com with subject "Speak Up".
• Anonymous web form: speakup.dfamachine.com, hosted by an independent third-party provider, available 24/7 in English, German and French.
• External authorities: you may also report to a "prescribed person" listed on gov.uk (e.g. ICO, HMRC, NCA) or the competent EU authority. No internal step is required first if you reasonably believe internal reporting would be ineffective.

We will protect the identity of anyone raising a concern to the fullest extent permitted by law. Anonymous reports are accepted and investigated; providing a contact channel (anonymous mailbox is fine) helps us ask follow-up questions and close the loop with you.

Any form of retaliation — dismissal, demotion, disciplinary action, blacklisting, exclusion, withholding work, intimidation — against someone who raises a concern in good faith, or who assists an investigation, is a serious disciplinary offence and may itself be a criminal act under the UK PIDA / EU Whistleblowing Directive. We will investigate every retaliation allegation with the same rigour as the underlying concern.

• Acknowledgement within 7 calendar days.
• Triage by an independent member of the Compliance Committee.
• Investigation by a suitably qualified person with no conflict of interest. External investigators are appointed where appropriate.
• Outcome and any corrective actions communicated to the reporter (within the bounds of confidentiality and legal restrictions) within 3 months.

Concerns raised in good faith are protected even if they turn out to be unfounded. Reports made maliciously, knowing them to be false, may result in disciplinary action.

The Speak Up programme is owned by the Compliance Committee and reviewed by the Board annually. Anonymised statistics are published in our annual compliance report. Investigation records are retained for 5 years.

For questions about this policy email contact@dfamachine.com.