ZYC-WHB-001 Whistleblowing Policy
Purpose
To ensure that all Zeyro staff and contractors can raise genuine concerns about wrongdoing safely, confidentially, and without fear of reprisal — in line with FCA SYSC 18 and the Public Interest Disclosure Act 1998.
Scope
Applies to all directors, employees, and contractors of Zeyro. Covers concerns about misconduct, regulatory breaches, unethical behaviour, or serious risks to clients, colleagues, or the public.
Policy Statement
Zeyro encourages an open culture where everyone feels able to speak up. Whistleblowing is not an act of disloyalty — it protects the integrity of the firm and its clients.
All disclosures will be handled discreetly, investigated fairly, and escalated appropriately. No whistleblower will suffer detriment, retaliation, or dismissal for raising a concern in good faith.
What Can Be Reported
Examples include:
Breaches of FCA or legal requirements
Money laundering or bribery
Data protection or confidentiality breaches
Misconduct or malpractice by staff or clients
Attempts to conceal any wrongdoing
Personal grievances (e.g., disputes about pay or workload) should be handled through HR rather than this policy.
Reporting Routes
Internal (Primary Route): Raise concerns in writing or verbally to the MLRO (SMF 16 & 17) at [email protected]. The MLRO will acknowledge receipt within 24 hours and investigate promptly.
Independent Oversight: If the concern relates to the MLRO, or the whistleblower is uncomfortable reporting internally, contact Giles Swan, Zeyro’s Non-Executive Director, via [email protected].
External Reporting: Staff may report directly to the FCA’s Whistleblowing Team if they believe internal channels are unsuitable. (Contact details: fca.org.uk/firms/whistleblowing)
Investigation Process
All disclosures are logged in the Whistleblowing Register in Confluence.
The MLRO or NED investigates objectively, maintaining confidentiality to the fullest extent possible.
Findings are reported to the Board with recommendations for any remedial action.
Outcomes and lessons learned are recorded, with access restricted to the MLRO and Board.
Protection and Confidentiality
Whistleblowers are protected under UK law and Zeyro policy.
Confidentiality will be maintained unless disclosure is required by law.
Retaliation or victimisation of whistleblowers is treated as a serious disciplinary matter.
Roles and Responsibilities (RACI)
Role
Responsibility
Accountability
Consulted / Informed
All Staff
Raise concerns in good faith; cooperate with investigations.
MLRO
MLRO / NED
MLRO (SMF 16 & 17)
Receive and investigate disclosures; maintain records; report to Board.
Board
NED
Non-Executive Director (Giles Swan)
Receive disclosures about MLRO or senior management; provide independent oversight.
Board
MLRO
Board
Review whistleblowing outcomes; ensure no retaliation occurs.
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MLRO / NED
Controls risk: ensures safe internal reporting and independent escalation consistent with FCA SYSC 18.
Review
This policy is reviewed annually or after any whistleblowing event, ensuring continued alignment with FCA and UK employment law.
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