Whistleblower Policy

Klarity Health (“Klarity”) is committed to the highest standards of integrity and accountability. This policy explains how anyone covered by it can raise concerns about wrongdoing, and the protections available to them when they do so in good faith.

This policy reflects the rights and protections available under the Public Interest Disclosure Act 1998 (“PIDA”), as amended.

This policy applies to all employees, workers, contractors, consultants, agency staff and former employees of Klarity.

A ‘protected disclosure’ under PIDA is one that relates to a matter of public interest. Qualifying disclosures include genuine concerns about:

• Criminal activity, including bribery, fraud or theft.

• Failure to comply with a legal obligation.

• Risk to health and safety of any individual.

• Damage to the environment.

• A miscarriage of justice.

• Deliberate concealment of any of the above.

This policy is not intended for personal grievances such as disputes about pay, working hours or individual performance. Those should be raised through Klarity’s grievance process.

If you have a concern, we encourage you to raise it as early as possible. You can do so in the following ways, in order of preference:

• Speak directly with a company director.

• Send a written report by email to a director, marked ‘Confidential – Protected Disclosure’.

If you do not feel comfortable reporting internally — for example because your concern involves a director — you may also report to a relevant external body or ‘prescribed person’ as defined by PIDA (for example, the Care Quality Commission or the Financial Conduct Authority, depending on the nature of the concern). The UK government maintains a current list of prescribed persons on its website.

Klarity will treat all disclosures with discretion. We will not reveal your identity without your consent unless we are required to do so by law or by a regulatory authority. In some investigations it may not be possible to maintain complete anonymity, and we will discuss this with you where it arises.

You may report anonymously, though this can make it more difficult to investigate your concern fully or keep you informed of the outcome.

Klarity will not subject any person to detriment for making a protected disclosure in good faith. Detriment includes dismissal, demotion, disciplinary action, being passed over for promotion, or any other form of unfair treatment.

If you believe you have suffered detriment as a result of a disclosure, you should raise this with a director immediately. You may also have rights under PIDA to bring a claim before an employment tribunal.

This policy is designed to support genuine concerns raised in good faith. Deliberately making false or malicious allegations is a serious disciplinary matter. Making an allegation in good faith that turns out to be unfounded will not itself result in any disciplinary action.

All disclosures will be acknowledged and assessed promptly. Where a concern warrants investigation, Klarity will appoint an appropriate person to lead that investigation. We will keep the person who raised the concern informed of progress, subject to confidentiality constraints.

This policy is reviewed annually. Questions about its application should be directed to a company director.