Speak-Up Policy — Mazel Grand HMS

Purpose

Mazel Grand HMS is committed to maintaining the highest standards of integrity, ethics, and compliance. This Speak-Up Policy provides a safe channel for raising concerns about wrongdoing, misconduct, or violations of our policies.

Speaking up protects our clients, colleagues, and the company. We encourage anyone with a genuine concern to report it without fear of retaliation.

Scope and applicability

This policy applies to all individuals who may have concerns about Mazel Grand HMS operations, including:

Employees and contractors of Mazel Grand HMS.
Clients and customers of Mazel Grand HMS.
Suppliers and partners working with Mazel Grand HMS.
Any other individual with a legitimate concern about our conduct.

What to report

You should use this channel to report genuine concerns about:

Illegal conduct: violations of law or regulation.
Unethical behaviour: actions that conflict with our ethical standards or Supplier Code.
Fraud and corruption: bribery, embezzlement, or financial misconduct.
Data protection breaches: unauthorised access to or disclosure of personal data.
Security incidents: vulnerabilities or breaches of our security systems.
Modern slavery: any evidence of forced labour or human trafficking in our operations or supply chain.
Health and safety: risks to the health or safety of workers or the public.
Retaliation: retaliation against someone who has raised a concern in good faith.
Misrepresentation: false or misleading statements about our services or capabilities.
Policy violations: breaches of our policies, including this one.

How to raise a concern

Concerns can be raised through the following channels:

Email: send your concern to info@mazelgrandhms.com with "Speak-Up" in the subject line.
Direct contact: raise the matter directly with a director or senior manager.
Anonymous: you may raise a concern anonymously, though this may limit our ability to investigate thoroughly.

What to include in your report

To help us investigate your concern effectively, please include as much detail as possible:

Description: a clear description of the concern or incident.
Who: the names or roles of individuals involved, if known.
When: when the incident or behaviour occurred.
Where: where the incident or behaviour took place.
Evidence: any documents, emails, or other evidence that supports your concern.
Witnesses: names of anyone else who may have witnessed the incident.
Contact information: if you are willing to be contacted for follow-up questions.

Confidentiality

We treat all reports confidentially and will not disclose your identity without your consent, except where required by law.

Limited disclosure: only those who need to know will be informed of your identity.
Anonymity: if you report anonymously, we will not attempt to identify you unless legally required.
Legal disclosure: we may be required to disclose information to law enforcement or regulators in certain circumstances.
Protection: we take reasonable steps to protect your identity from retaliation.

No retaliation

We have zero tolerance for retaliation against anyone who raises a concern in good faith.

Protection: individuals who raise concerns in good faith are protected from retaliation, harassment, or discrimination.
No detriment: you will not suffer any professional, personal, or financial detriment for speaking up.
Retaliation as misconduct: retaliation against a whistleblower is itself a serious disciplinary matter.
Report retaliation: if you experience retaliation for raising a concern, report it immediately using this same channel.

Good faith reporting

This policy is designed for genuine concerns raised in good faith. Good faith means you genuinely believe the concern is true, even if it turns out to be mistaken.

Mistaken reports: if you raise a concern that turns out to be unfounded but was made in good faith, you will not face consequences.
Malicious reports: deliberately false or malicious reports made to harm someone are not protected and may result in disciplinary action.
Evidence of good faith: we assess good faith based on the information provided and the context of the report.

Investigation process

When we receive a concern, we follow a structured investigation process:

Acknowledgement: we acknowledge receipt of your concern within 2 business days.
Initial assessment: we assess the concern to determine its seriousness and whether it falls within this policy.
Investigator assignment: the concern is assigned to an investigator who is not involved in the matter.
Investigation: the investigator gathers evidence, interviews witnesses, and reviews relevant documents.
Findings: the investigator prepares a report with findings and recommendations.
Action: appropriate action is taken based on the findings, including disciplinary action if warranted.

Timeline

We aim to complete investigations as quickly as possible while being thorough:

Acknowledgement: within 2 business days of receiving your concern.
Initial assessment: within 5 business days, we will determine the scope of investigation.
Investigation completion: typically within 20-30 business days, depending on complexity.
Outcome communication: we will communicate the outcome to you as far as confidentiality allows.

Outcomes and follow-up

After investigation, possible outcomes include:

No action: if the concern is unfounded or cannot be substantiated, no action is taken.
Corrective action: if the concern is substantiated, we take corrective action to address the issue.
Disciplinary action: if misconduct is found, we may take disciplinary action up to and including termination.
Referral to authorities: if the concern involves illegal conduct, we may refer it to law enforcement or regulators.
Policy review: if the concern reveals a gap in our policies, we may update our policies to prevent recurrence.

Feedback to the reporter

We will provide feedback to the person who raised the concern, subject to confidentiality considerations:

Outcome summary: we will inform you of the general outcome of the investigation.
Confidentiality limits: we may not be able to share specific details if it would compromise confidentiality or legal obligations.
Anonymous reports: if you reported anonymously, we may not be able to provide feedback unless you provide contact information.

External reporting channels

While we encourage internal reporting first, you may also raise concerns externally if you prefer:

Regulators: you may report concerns to relevant regulatory bodies where applicable.
Law enforcement: you may report illegal conduct to police or other law enforcement agencies.
Legal advice: you may seek legal advice before raising a concern, especially if you are unsure about your rights.

Support for reporters

We recognise that raising a concern can be stressful. We offer support to individuals who raise concerns:

Confidential counselling: we can provide access to confidential counselling services if needed.
Support during investigation: we will keep you informed of progress and protect you from retaliation.
No pressure: we will not pressure you to participate in the investigation beyond what you are comfortable with.

Record-keeping

We maintain records of concerns raised and investigations conducted:

Confidential records: records are kept confidential and securely stored.
Retention period: records are retained in accordance with our data retention policy.
Audit trail: records provide an audit trail of how concerns were handled.

Policy review

This policy is reviewed annually to ensure it remains effective and compliant with legal requirements. We may update it based on feedback, legal changes, or best practices.

Contact

To raise a concern: info@mazelgrandhms.com (subject line: "Speak-Up").

Questions about this policy: info@mazelgrandhms.com.

If you prefer to speak to a director directly, contact us for the appropriate contact information.