Introduction
Nex Global LLC, trading as Nex Systems (Nex), helps organisations detect wrongdoing. We expect the same honesty of ourselves, and we want to know if something is wrong inside Nex or in how others act in Nex's name.
This Speak-Up Policy (the Policy) explains how to raise a concern safely, how Nex will deal with it, and how people who speak up are protected. Speaking up is the right thing to do. Nobody will suffer for raising a genuine concern, even if it turns out to be mistaken.
This Policy supports the Anti-Bribery and Corruption Policy and the Sanctions Compliance Statement, and applies alongside any rights a person has under the law.
1. Who Can Speak Up and About What
1.1 Who. Anyone can use this Policy, including Nex employees, managers, contractors, interns and job applicants; former staff; Authorised Partners, referrers and suppliers and their staff; customers; and members of the public.
1.2 What. Concerns may be about suspected or actual:
- (a) bribery, corruption, kickbacks or improper payments;
- (b) fraud, theft, money laundering or terrorist financing;
- (c) breaches of sanctions or export controls;
- (d) misuse of Customer Data or personal data, or security weaknesses being hidden;
- (e) conflicts of interest that have not been disclosed;
- (f) false records, accounts or claims, including false statements to customers or regulators;
- (g) harassment, discrimination, modern slavery or human rights abuses;
- (h) risks to health and safety or the environment;
- (i) breaches of law, regulation or Nex policies; and
- (j) any attempt to hide any of the above, or to retaliate against someone who raised a concern.
1.3 Not covered. Personal workplace grievances that do not involve wrongdoing, such as a disagreement about pay or workload, should be raised through normal management channels. Customer complaints about service quality should be raised under the Complaints Handling Policy.
1.4 Reasonable belief. You do not need proof. You only need a reasonable belief that something may be wrong. Please do not investigate the matter yourself.
2. How to Raise a Concern
2.1 Channels. You can raise a concern:
- (a) by email to compliance@nex.systems, which is read only by the Compliance Officer and authorised members of senior management;
- (b) with your manager or your usual Nex contact, if you are comfortable doing so; or
- (c) directly with a member of Nex senior management, if the concern involves the Compliance Officer.
2.2 What to include. Where possible, describe what happened, when and where, who was involved, how you know, and any documents or evidence. Do not include more personal data than needed.
2.3 Meeting. If you prefer, you can ask for a call or meeting to explain your concern, and you may be accompanied by a colleague.
3. Confidentiality and Anonymity
3.1 Confidentiality. Nex will keep your identity and the details of your concern confidential, sharing them only with those who need to know to investigate or act, or where the law requires disclosure. Your identity will not be disclosed to the person you report without your consent, unless the law requires it.
3.2 Anonymity. You may raise a concern anonymously, for example from an email address that does not identify you. Anonymous concerns will be taken seriously, but they can be harder to investigate, because Nex cannot ask follow-up questions. Please consider giving a way to contact you.
3.3 Data protection. Personal data in a concern is processed only for handling and investigating it, kept securely, and retained in line with section 7.
4. How Concerns Are Handled
4.1 Steps and timelines.
| Step | Target |
|---|---|
| Acknowledge receipt | Within 7 days |
| Initial assessment of whether and how to investigate | Within 14 days |
| Feedback to you on the action taken or planned | Within 3 months of acknowledgement |
4.2 Independence. Concerns are assessed and investigated by people who are independent of the matter. Nex may appoint external investigators or advisers.
4.3 Feedback. Nex will tell you, as far as it can, what action has been taken. Confidentiality and legal obligations to others may limit the detail Nex can share.
4.4 Outcome. Where wrongdoing is found, Nex will act to stop it, correct its effects and prevent it recurring, which may include disciplinary action, ending a business relationship, and reporting to the authorities.
5. Protection from Retaliation
5.1 Zero tolerance. Nex will not tolerate retaliation of any kind against anyone who raises a concern in good faith, helps with an investigation, or refuses to take part in wrongdoing. Retaliation includes dismissal, demotion, loss of pay or work, threats, harassment, exclusion, negative references, and ending or penalising a partner, referrer or supplier relationship.
5.2 Consequences. Anyone who retaliates, or tries to identify an anonymous reporter without authority, will face disciplinary action up to and including dismissal, or termination of the business relationship.
5.3 If you experience retaliation. Report it immediately through any channel in section 2. It will be treated as a new and serious concern.
5.4 False reports. Protection does not extend to someone who knowingly makes a false report. Making a report that turns out to be mistaken is not a false report.
6. Reporting to Authorities
6.1 Nex encourages people to raise concerns internally first, so that Nex can act quickly. However, nothing in this Policy, in any Nex contract, confidentiality obligation or settlement agreement prevents or restricts anyone from:
- (a) reporting possible breaches of law to a regulator, law enforcement agency or other competent authority;
- (b) cooperating with, or giving information to, such an authority; or
- (c) exercising any right they have under whistleblower protection laws.
No one needs Nex's permission to do so, or needs to tell Nex that they have done so.
7. Records, Governance and Contact
7.1 Records. Nex keeps a secure record of each concern, the investigation and the outcome for at least five (5) years after the matter is closed, or longer where the law or a legal claim requires.
7.2 Oversight. The Compliance Officer is responsible for this Policy and reports a summary of concerns, without identifying reporters, to senior management at least annually.
7.3 Awareness. Nex Personnel are told about this Policy when they join and in annual compliance training. Partners, referrers and suppliers receive it with the Anti-Bribery and Corruption Policy.
7.4 Review. This Policy is reviewed at least annually, in line with ISO 37002. Nex may update it by publishing a revised version at www.nex.systems
7.5 Contact. compliance@nex.systems Nex Global LLC, trading as Nex Systems, Wyoming, United States.
Common questions
Short answers for orientation. The document above governs if anything differs.
Anyone, including employees, contractors, job applicants, former staff, partners, referrers, suppliers, customers and members of the public. Concerns can cover bribery, fraud, money laundering, sanctions breaches, data misuse, false records, harassment, modern slavery, safety risks, other breaches of law or policy, and retaliation (see Section 1).