Speak Up Safely

Whistleblowing Policy

TalaStar Digital Ltd is committed to conducting business with integrity. This policy provides a safe, confidential framework for raising concerns about wrongdoing, in accordance with the Public Interest Disclosure Act 1998 (PIDA).

Effective: April 2026 · Version 1.0 · Approved by: Kristal Jane Apurado, Director

A Note on Honesty

TalaStar Digital Ltd (Company No. 17060305) was incorporated on 27 February 2026 and is currently an early-stage, sole-founder company. Kristal Jane Apurado is the only employee. We publish this Whistleblowing Policy voluntarily because we believe that ethical governance should begin at founding, not after a crisis. As we grow, this policy will evolve — but the commitment to protecting those who speak up will not change.

Scope & Purpose

This policy applies to all individuals who work with or for TalaStar Digital Ltd, including employees, contractors, consultants, suppliers, interns, and any person who has a working relationship with the company.

The purpose of this policy is to encourage individuals to raise genuine concerns about suspected wrongdoing at the earliest possible stage, through appropriate channels, without fear of retaliation. It complements — but does not replace — other procedures such as our grievance or complaints processes.

A "qualifying disclosure" under PIDA 1998 is any disclosure of information that, in the reasonable belief of the worker, is made in the public interest and tends to show that one or more of the following has occurred, is occurring, or is likely to occur.

What You Can Report

Financial Misconduct

  • Fraud, bribery, or corruption in any business dealings
  • Deliberate misrepresentation of financial information
  • Misuse of company funds or assets

Legal & Regulatory Violations

  • Breaches of UK data protection law (UK GDPR / DPA 2018)
  • Non-compliance with the Companies Act 2006
  • Violations of anti-money laundering regulations

Health, Safety & Environment

  • Conditions that endanger the health or safety of any person
  • Environmental damage or risk of environmental damage
  • Failure to comply with workplace safety obligations

Ethical & Human Rights Concerns

  • Modern slavery or human trafficking in our supply chain
  • Discrimination, harassment, or bullying
  • Misuse of AI systems that could cause harm to individuals

Data & Technology Misuse

  • Unauthorised access to or misuse of personal data
  • Deliberate introduction of security vulnerabilities
  • Use of AI systems in ways that violate our Code of Ethics

How to Report a Concern

Direct Disclosure

Raise concerns directly with the Founder & Director, Kristal Jane Apurado, at [email protected] or [email protected].

Preferred for internal matters. All disclosures treated with strict confidence.

External Prescribed Persons

If you believe internal reporting is inappropriate, you may disclose to a prescribed person or body under PIDA 1998.

Examples: Information Commissioner's Office (ICO), Financial Conduct Authority (FCA), Serious Fraud Office (SFO).

Protect (Whistleblowing Charity)

Independent, confidential advice on whistleblowing rights and procedures.

Helpline: 020 3117 2520 · Website: protect-advice.org.uk

Your Protections

Confidentiality

The identity of any person making a disclosure is treated as strictly confidential. We will not reveal your identity without your consent unless required by law.

Protection from Retaliation

Under PIDA 1998, workers who make qualifying disclosures are protected from dismissal, disciplinary action, or any form of detriment. TalaStar extends this protection to all individuals who engage with us, including suppliers and contractors.

Good Faith Principle

Protections apply to disclosures made in good faith with a reasonable belief that the information is substantially true. Malicious or knowingly false reports are not protected.

No Requirement to Prove

You do not need to prove that wrongdoing has occurred. A reasonable belief that the information tends to show one of the categories of concern is sufficient.

Investigation Process

01

Acknowledgement

All disclosures are acknowledged within 5 working days. You will be informed of who is handling your concern.

02

Initial Assessment

The nature and seriousness of the concern is assessed to determine the appropriate investigation approach.

03

Investigation

A proportionate investigation is conducted. Where the concern involves the Director, an independent external party will be engaged.

04

Outcome & Action

You will be informed of the outcome where possible, subject to legal and confidentiality constraints. Corrective action is taken where wrongdoing is confirmed.

Legal Framework

This policy is informed by the Public Interest Disclosure Act 1998 (PIDA), which provides statutory protection for workers who make qualifying disclosures about wrongdoing. PIDA was amended by the Enterprise and Regulatory Reform Act 2013 to require that disclosures be made in the public interest.

The categories of qualifying disclosure under PIDA Section 43B include: criminal offences, failure to comply with legal obligations, miscarriages of justice, danger to health and safety, damage to the environment, and deliberate concealment of information relating to any of these matters.

This policy also aligns with the principles of the UK Corporate Governance Code (where applicable to our future growth), the FCA's whistleblowing requirements for regulated firms (which TalaStar is not currently subject to, but aspires to meet proactively), and the guidance issued by the charity Protect (formerly Public Concern at Work).

Kristal Jane Apurado

Founder & Director, TalaStar Digital Ltd

Company No. 17060305 · Registered in England and Wales

This policy was approved in April 2026 and will be reviewed annually or following any significant change in legislation or company structure.