Effective Date: 18/02/2026
Review Date: 17/02/2027
Policy Owner: Ed Williamson-Smit, Founder & Managing Director

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1. Purpose

Here Now Films Ltd is committed to maintaining the highest standards of honesty, integrity, and accountability. We recognise that individuals working for or with us are often the first to become aware of potential wrongdoing. This policy exists to encourage and enable anyone to raise genuine concerns internally, without fear of reprisal, so that issues can be addressed promptly and appropriately.

This policy is intended to complement, not replace, other company policies and procedures such as our Anti-Bribery & Anti-Corruption Policy and any grievance procedures.

2. Scope

This policy applies to all individuals working for or on behalf of Here Now Films, including directors, employees (permanent, fixed-term, or part-time), freelancers, contractors, and any third party engaged by the company.

Whistleblowing is the disclosure of information that relates to suspected wrongdoing or dangers at work. This is distinct from a personal grievance (such as a complaint about your own employment terms), which should be raised through the company’s grievance procedure.

3. What Concerns Are Covered?

You are encouraged to raise concerns about any of the following, whether occurring now, having occurred in the past, or likely to occur in the future:

• Criminal activity or fraud
• Bribery or corruption
• A failure to comply with a legal or regulatory obligation
• A miscarriage of justice
• A danger to the health and safety of any individual
• Damage to the environment
• A deliberate attempt to conceal any of the above

This list is not exhaustive. If you are unsure whether your concern qualifies, you are encouraged to raise it anyway — it is better to report a concern that turns out to be unfounded than to stay silent about something that may cause harm.

4. Legal Protection

Under the Public Interest Disclosure Act 1998 (PIDA), workers who make a qualifying disclosure are protected from dismissal or detrimental treatment. Here Now Films fully supports this protection and will not tolerate any form of retaliation against anyone who raises a genuine concern in good faith.

This protection applies even if the concern turns out to be mistaken, provided it was raised honestly and with a reasonable belief that it was in the public interest.

5. How to Raise a Concern

Step 1 — Raise it internally

In the first instance, concerns should be raised with the Managing Director, either verbally or in writing (including by email). You should include as much detail as possible, including relevant dates, names, and any supporting information or documentation.

You are not expected to investigate the matter yourself or to have proof — a genuine suspicion is enough.

Contact: Ed [Surname], Managing Director Email: [Insert email address]

Step 2 — If the concern involves the Managing Director

If your concern relates to the Managing Director, or you feel unable to raise it with them for any reason, you should contact:

[Insert alternative contact — e.g. the company’s accountant, solicitor, or a nominated non-executive adviser]

Name: [Insert name] Email: [Insert email address]

Step 3 — External reporting

If you have raised a concern internally and feel it has not been adequately addressed, or if you believe the matter is too serious to raise internally, you have the right to report it to a relevant external body. These include:

• HMRC — for tax fraud or national minimum wage concerns
• Health and Safety Executive (HSE) — for health and safety risks
• Environment Agency — for environmental damage
• Financial Conduct Authority (FCA) — for financial misconduct
• The Information Commissioner’s Office (ICO) — for data protection breaches
• The police — for criminal activity

You can also contact the independent whistleblowing charity Protect (formerly Public Concern at Work) for confidential advice: www.protect-advice.org.uk / 020 3117 2520.

6. Anonymity & Confidentiality

You may raise concerns anonymously. However, we encourage you to identify yourself where possible, as this makes it significantly easier to investigate the matter, ask follow-up questions, and provide you with feedback.

Where you do identify yourself, your identity will be kept confidential to the greatest extent possible. It will only be disclosed where necessary for the purposes of the investigation or where required by law.

7. How We Will Respond

On receiving a concern, the Managing Director (or alternative contact) will:

• Acknowledge receipt of the concern, normally within five working days.
• Assess the concern and determine the appropriate course of action, which may include an internal investigation, referral to an external body, or other steps as appropriate.
• Keep the person who raised the concern informed of progress where possible, while respecting the confidentiality of others involved.
• Aim to resolve the matter as promptly as the circumstances allow.

Some concerns may be resolved quickly; others may require more detailed investigation. In all cases, the matter will be taken seriously and handled with care.

8. Protection Against Retaliation

Here Now Films will not tolerate any form of retaliation, harassment, victimisation, or detrimental treatment directed at anyone who raises a genuine concern under this policy. This applies regardless of the outcome of any investigation.

Any individual found to have retaliated against a whistleblower will face disciplinary action, which may include dismissal or termination of engagement.

9. Malicious or Vexatious Disclosures

While this policy is designed to protect genuine concerns raised in good faith, it must not be used to raise knowingly false or malicious allegations. Any individual found to have deliberately made a false disclosure may face disciplinary action.

10. Record Keeping

The Managing Director will maintain a confidential record of all concerns raised under this policy, including the nature of the concern, how it was investigated, and the outcome. These records will be retained securely and in accordance with data protection legislation.

11. Review

This policy will be reviewed annually, or sooner if required by changes to legislation or the nature of the company’s activities. All team members will be notified of any significant changes.