Speak Up Policy

1. Purpose and Commitment

INTELLIGENCE AI LTD is committed to conducting business legally, ethically, and responsibly. We expect all employees, directors, officers, contractors, freelancers, suppliers, business partners, customers, and other stakeholders to share that commitment. Our Speak Up Policy is designed to make it easy and safe for anyone to raise a concern about wrongdoing, misconduct, or unethical behaviour without fear of retaliation.

This policy is intended to operate alongside the protections available under the UK Public Interest Disclosure Act 1998 ("PIDA"), which protects workers who make qualifying disclosures in the public interest from detriment or unfair dismissal. We encourage anyone who is uncertain whether a concern falls within PIDA to seek independent advice, but we also want you to feel able to raise concerns with us directly in the first instance.

2. Scope and Who Can Use This Policy

This policy applies to everyone who interacts with INTELLIGENCE AI LTD, including:

• Current and former employees and directors
• Contractors, freelancers, consultants, and agency staff
• Suppliers, subcontractors, and business partners
• Customers, users, and members of the public who become aware of a concern

Concerns may relate to conduct anywhere in our business, including our UK operations, remote work, supplier relationships, customer engagements, and the technology and payment services we rely on (such as Stripe). Concerns may be raised by individuals or on behalf of a group.

3. What to Report

We encourage you to speak up about any genuine concern, even if you are not certain that wrongdoing has occurred. The following list gives examples of matters that should be reported, but it is not exhaustive:

• Bribery, corruption, fraud, theft, money laundering, terrorist financing, or sanctions evasion
• Financial irregularities, false accounting, or misleading financial or operational reporting
• Modern slavery, forced labour, human trafficking, child labour, or other serious human rights abuses
• Failure to comply with the Modern Slavery Act 2015, Bribery Act 2010, or other applicable UK law
• Data protection breaches, misuse of personal data, or violations of UK GDPR or the Data Protection Act 2018
• Security incidents, cyber vulnerabilities, or failure to follow information security obligations
• Harassment, bullying, discrimination, victimisation, or other breaches of workplace dignity
• Health and safety failures or risks to workers, customers, or the public
• Environmental harm or breaches of environmental law or policy
• Conflicts of interest or failures to declare gifts and hospitality
• Anticompetitive behaviour, cartels, or other breaches of competition law
• Retaliation against someone who has raised a concern in good faith
• Any other criminal offence, breach of a legal obligation, miscarriage of justice, danger to health or safety, damage to the environment, or deliberate concealment of any of these matters

Personal grievances, such as complaints about your own pay, performance management, or interpersonal disagreements, should generally be raised through our normal HR, management, or grievance channels. However, if a personal grievance raises a wider public interest concern, it may also be reported under this policy.

4. How to Report a Concern

4.1 Internal reporting channels

You can raise a concern in any of the following ways:

• Speak to your line manager, project lead, or another trusted manager
• Contact the compliance lead or a member of the senior leadership team directly
• Submit a report through the contact page on our website
• Email us at info@intelligenceailtd.com with the subject line "Speak Up Report"

4.2 Anonymous reports

You may choose to report anonymously if you prefer. Where you do so, please provide as much detail as possible so that we can investigate effectively. We will take anonymous reports seriously, although we may be limited in our ability to follow up with you if we do not have contact details.

4.3 External reporting

If you do not feel able to raise your concern internally, or if you are not satisfied with our response, you may be able to report to an external body. Depending on the subject matter, this could include the police, the National Crime Agency, the Information Commissioner's Office, the Health and Safety Executive, the Serious Fraud Office, HM Revenue & Customs, or a prescribed person or body under PIDA. We encourage you to take independent legal advice if you are considering an external disclosure.

5. Information to Include in a Report

To help us investigate your concern effectively, please include, where possible:

• A clear description of the concern, including what happened, when, and where
• The names of any individuals, organisations, customers, or suppliers involved
• Any evidence, documents, screenshots, emails, or other supporting material
• Whether you believe the issue is ongoing or has already occurred
• Whether anyone else has witnessed the conduct or may be able to provide further information
• Your contact details, unless you wish to remain anonymous
• Any steps you have already taken to raise or resolve the concern

6. Confidentiality and Data Protection

We will handle all reports, and the identity of the person raising the concern, with appropriate confidentiality. We will only disclose information to those who need to know in order to investigate the concern, comply with legal obligations, or protect our legitimate interests.

Personal data provided in connection with a report will be processed in accordance with UK GDPR, the Data Protection Act 2018, and our Privacy Policy. We will only keep information for as long as necessary to investigate, take remedial action, defend legal rights, or comply with legal obligations.

7. Protection Against Detriment and Retaliation

INTELLIGENCE AI LTD does not tolerate any form of retaliation, victimisation, bullying, harassment, discrimination, or other adverse treatment directed at anyone because they have raised a concern in good faith under this policy. This applies regardless of whether the concern is ultimately substantiated.

Retaliation may take many forms, including dismissal, demotion, denial of opportunities, exclusion, threats, abusive treatment, or damage to reputation. Anyone found to have retaliated against a person who raised a concern in good faith will be subject to disciplinary or other appropriate action, which may include termination of employment or business relationship. If you believe you have experienced retaliation as a result of using this policy, you should report it immediately under this same procedure.

In addition to the protections under this policy, UK workers may have rights under PIDA if they make a qualifying protected disclosure in the public interest. Nothing in this policy is intended to override those statutory protections.

8. Investigation Process

8.1 Initial assessment

All reports will be acknowledged as soon as practicable. A nominated person will carry out an initial assessment to determine whether the concern falls within this policy, whether it is urgent, and what the appropriate next steps are.

8.2 Investigation

Where an investigation is required, we will appoint an impartial person or team to conduct it. The scope, method, and timing of the investigation will depend on the nature and seriousness of the concern. Investigations may involve reviewing documents, interviewing witnesses, analysing systems or data, and consulting external advisers or regulators.

8.3 Reporting outcomes

Where it is appropriate and lawful to do so, we will inform the person who raised the concern of the outcome of the investigation and any action taken. In some cases, for example where there are legal, confidentiality, or data protection reasons, we may only be able to provide a general update.

8.4 Record keeping

We will keep a confidential record of the report, the steps taken to investigate, the findings, and any remedial action. Records will be retained only for as long as necessary for legal, regulatory, or business purposes.

9. Concerns Relating to Payment Processing and Stripe

INTELLIGENCE AI LTD uses Stripe, Inc. as its payment processor. Concerns relating to payment security, suspected fraud, money laundering, sanctions evasion, or other financial crime connected to payments on our platform should be reported under this policy. We will assess such concerns in accordance with our anti-financial-crime obligations and our KYC / AML Policy.

If a concern relates specifically to Stripe's own systems, processes, or personnel, you may also report it directly to Stripe through its own reporting channels. We will cooperate with Stripe, regulators, or law enforcement where required.

10. Malicious, Vexatious, or False Reports

This policy is intended for genuine concerns raised in good faith. Reports that are knowingly false, malicious, or vexatious are not protected and may result in disciplinary action, termination of a business relationship, or legal proceedings. A report made in good faith, even if it is later found to be unsubstantiated, will not be treated as malicious or false simply because the underlying concern could not be proven.

11. Review and Updates

We review this Speak Up Policy regularly to ensure that it remains effective and consistent with changes in law, regulation, and our business. We may update this page at any time, and the "Last updated" date will be revised accordingly.

12. Contact Us

If you have any questions about this Speak Up Policy or would like to raise a concern, please contact us via the contact page on our website, or by email at info@intelligenceailtd.com.