We are committed to maintaining a responsible, respectful, and transparent business environment in which employees, contractors, suppliers, consultants, professional partners, and other individuals connected with our operations can raise serious concerns without fear of retaliation. Speaking up about potential wrongdoing can help identify significant problems before they become more serious and can support appropriate action when unlawful, unethical, unsafe, or otherwise unacceptable conduct is suspected.
This Whistleblowing Policy explains how serious concerns may be reported and how those concerns may be reviewed, investigated, and addressed. Whistleblowing is generally intended for matters involving substantial misconduct, violations of applicable law, serious ethical concerns, significant risks to people or the environment, misuse of business resources, financial wrongdoing, or attempts to hide improper conduct. The purpose of this policy is to provide an appropriate channel through which individuals can bring serious concerns to attention.
Not every workplace concern will necessarily fall within the scope of this policy. Ordinary employment disagreements, interpersonal conflicts, questions about management practices, individual performance issues, bullying, harassment, discrimination, or other personal grievances may be more appropriately handled through a separate complaint, workplace support, or employee relations process. If an individual is uncertain about which procedure applies, they may contact us for guidance before deciding how to submit the concern.
Matters that may be appropriate for whistleblowing consideration can include suspected criminal conduct, unlawful business activity, bribery, corruption, fraudulent behavior, inaccurate financial reporting, theft, misuse of company property, serious safety failures, substantial environmental harm, exploitation, forced labor, conduct that could place employees or members of the public at significant risk, and deliberate attempts to conceal wrongdoing. Serious violations of legal duties, professional standards, or important internal requirements may also be considered where appropriate.
A report may concern conduct that occurred previously, is currently taking place, or is reasonably believed to be likely to occur. Individuals are encouraged to report concerns as soon as reasonably possible when they have a genuine basis for believing that a serious issue exists. A reporting individual does not need to possess complete proof before raising a concern. However, information should be provided honestly and should be based on facts, observations, records, communications, circumstances, or other information that gives the individual a reasonable basis for making the disclosure.
This reporting process may be used by people who have different types of relationships with our business. This can include employees, temporary personnel, contractors, consultants, suppliers, service providers, professional advisers, commercial partners, and other individuals who become aware of potentially serious misconduct through their work or business relationship with us.
Reports may be submitted by email at bathsbomb@gmail.com. Individuals should provide as much relevant information as they reasonably can, including a description of the concern, the activities or individuals involved, approximate dates or time periods, locations where relevant, available documents, communications, and any other information that could help establish the circumstances. Providing specific and factual information can assist with an efficient and appropriate assessment.
Where circumstances allow, an individual may raise a concern without identifying themselves. We will make reasonable efforts to protect information relating to a whistleblowing disclosure and to limit access to those who have a legitimate need to review or manage the matter. Confidentiality may be subject to applicable legal requirements and the practical needs of a fair and effective investigation.
Anonymous reporting can sometimes make an investigation more difficult because investigators may not be able to ask follow-up questions, clarify information, obtain additional documentation, or provide updates to the reporting person. Even so, a concern will not be disregarded solely because the person making the disclosure has chosen not to identify themselves. Available information will be considered based on the circumstances and the seriousness of the reported issue.
After a concern is received, an initial assessment may be conducted to determine its nature, seriousness, scope, and appropriate next steps. Depending on the circumstances, the review may involve examining relevant business records, gathering documents, reviewing communications, assessing available evidence, speaking with individuals who may have relevant knowledge, or conducting other reasonable inquiries.
Investigations will be approached with appropriate care and discretion. The specific process may differ depending on the nature of the allegation, the information available, the people involved, the potential risks, and any applicable legal requirements. Not every report will necessarily result in a formal investigation. Some matters may be referred to another appropriate internal process or addressed through another suitable channel.
Where the identity and contact details of the reporting individual are available, we may request additional information during the review. Providing clarification or supporting material can assist in establishing the facts. Where appropriate, we may provide general information about the progress or conclusion of a matter, although there may be circumstances in which detailed information cannot be shared.
Investigative information may be subject to privacy obligations, employment considerations, confidentiality requirements, legal restrictions, or other limitations. For these reasons, we may not be able to disclose specific findings, disciplinary measures, personal information, or details concerning actions taken against another individual. Limiting the disclosure of such information does not necessarily mean that a concern has not been reviewed.
Retaliation against a person who raises a legitimate concern honestly and in good faith is not permitted. Retaliation may include threats, intimidation, dismissal, discrimination, unfavorable treatment, inappropriate disciplinary action, or other adverse conduct that occurs because an individual made a genuine disclosure or assisted with an investigation.
Anyone who believes they have experienced retaliation connected with a whistleblowing report should communicate the concern as soon as reasonably possible. Allegations of retaliation may be reviewed separately from the original matter so that the circumstances can be assessed appropriately.
Individuals using this policy are expected to act honestly and responsibly. The purpose of whistleblowing protection is to support genuine disclosures, not knowingly false allegations or deliberately misleading statements. A person does not need to be certain that wrongdoing has occurred, but they should have a reasonable basis for raising the concern. Reports that are intentionally fabricated, maliciously submitted, or knowingly false may not receive the same protections associated with good-faith reporting.
Where deliberate misuse of the reporting process is established, appropriate action may be considered in accordance with applicable law, contractual obligations, workplace requirements, and the circumstances involved. Honest mistakes, misunderstandings, or concerns that ultimately cannot be substantiated will not automatically be treated as bad-faith reports.
Information submitted through the whistleblowing process may include confidential or personal information. We will seek to handle such information responsibly and use it only to the extent reasonably necessary to assess, investigate, manage, or resolve the reported concern. Access may be limited to individuals who have a legitimate role in the relevant review or response.
Records connected with whistleblowing matters may be retained for as long as reasonably necessary to assess the concern, conduct an investigation, document the outcome, manage related issues, or meet applicable legal, regulatory, contractual, accounting, or business requirements. When identifiable information is no longer reasonably required, it may be securely deleted, anonymized, or otherwise disposed of in accordance with applicable requirements.
Individuals considering an anonymous report should understand that anonymity may affect the ability to verify certain allegations. Without the reporting person’s identity or ability to provide additional information, investigators may be unable to clarify important details or obtain supporting evidence. Nevertheless, anonymous disclosures will be assessed using the information reasonably available at the time.
Nothing in this policy prevents an individual from contacting an appropriate government authority, regulator, law enforcement organization, or other external body when such reporting is permitted or required by law. Different jurisdictions may provide specific whistleblower protections, reporting mechanisms, confidentiality rights, or remedies. Individuals should consider the laws applicable to their circumstances when deciding whether to use an internal reporting channel, an external authority, or both.
Where an employee, contractor, supplier, or other person connected with our operations is found to have violated applicable requirements, reasonable action may be considered based on the facts and circumstances. Any employment, contractual, commercial, or other consequences will depend on applicable agreements, internal requirements, governing law, and the nature and seriousness of the conduct.
We may periodically review and update this policy to reflect changes in our operations, reporting channels, legal obligations, or business practices. Updates may be introduced to improve the effectiveness of the reporting process, strengthen confidentiality practices, clarify responsibilities, or respond to changes in applicable law.
Where mandatory legal requirements provide protections or procedures that differ from this policy, those requirements will apply to the extent legally required. Nothing in this policy is intended to limit a person’s statutory rights or prevent lawful reporting to an appropriate authority.
Individuals with questions about this policy, reporting procedures, confidentiality, retaliation, or suspected serious misconduct may contact us at bathsbomb@gmail.com. When submitting a report, individuals are encouraged to provide enough factual information to allow the concern to be understood and appropriately assessed.
Our objective is to maintain a business environment in which serious concerns can be raised responsibly, reviewed carefully, and addressed in an appropriate manner. We recognize that effective whistleblowing arrangements depend on good-faith reporting, reasonable confidentiality, fair assessment, responsible investigation, and protection against retaliation. We encourage individuals who become aware of serious potential wrongdoing connected with our operations to speak up through an appropriate reporting channel.