Purpose

Peppy Health is committed to fostering a culture of integrity, transparency, and accountability.
This Whistleblower Protection Policy ensures that stakeholders who raise concerns in good
faith are protected from retaliation, discrimination, or adverse consequences. It outlines
mechanisms to enforce confidentiality, manage risks, and respond to grievances in a fair and
impartial manner.

1. Commitment to Protecting Whistleblowers

Peppy Health pledges to:

  • Protect whistleblowers: Ensure that anyone raising concerns through our grievance or
    complaints mechanism is safeguarded against retaliation.
  • Uphold confidentiality: Limit information sharing to only those directly involved in
    resolving the matter.
  • Promote a safe environment: Encourage reporting without fear, supporting an open
    and ethical workplace culture.

2. Retaliation and Consequences

  • Definition of Retaliation:
    Retaliation includes, but is not limited to, dismissal, demotion, harassment, discrimination, or
    any form of adverse treatment resulting from whistleblowing.

  • Zero Tolerance for Retaliation:
      Peppy Health will take immediate action if retaliation is identified, which may include:

    • Disciplinary measures, up to and including termination, for individuals found
      engaging in retaliatory behavior.
    • Remediation efforts to address the impact on the whistleblower, such as
      reinstatement or compensation, where appropriate.

3. Whistleblower Protection Mechanisms

To safeguard whistleblowers, Peppy Health has implemented the following measures:

a. Confidentiality

  • Information related to a whistleblower’s identity and complaint will only be shared on a
    need-to-know basis.
  • Consent will be sought before involving additional parties in the resolution process.
  • Outcomes of investigations will remain confidential to protect all parties involved.

b. Risk Assessment

  • Independent third parties may be engaged to assess potential risks for whistleblowers,
    particularly in cases involving vulnerable stakeholders.

c. Independent Reporting Channels

  • A secure whistleblower hotline and online reporting form ensure anonymity, if desired.
  • Reports can be submitted to people@peppy.health

d. Grievance Handling Training

  • Employees handling whistleblower complaints will receive enhanced training to manage
    grievances fairly and sensitively, ensuring compliance with confidentiality and protection
    measures.

e. Disciplinary Action for Breaches

  • Any breach of confidentiality or retaliation will result in immediate disciplinary action,
    including termination, where warranted.

f. Collaboration with Third Parties

  • External advisors or auditors may be engaged to independently evaluate cases or
    provide additional protection to whistleblowers, particularly in complex or high-risk
    situations.

4. Best Practices for Handling Grievances

Peppy Health ensures:

  • Transparency: Whistleblowers are informed at the outset about who will be involved in
    the process.
  • Consent Management: Whistleblowers’ consent is sought before sharing information
    beyond the core resolution team.
  • Confidentiality Assurance: The outcome of the process is communicated only to
    relevant parties, ensuring privacy.
  • Continuous Improvement: Regular training for employees handling grievances ensures
    a high standard of care and compliance with best practices.

5. Reporting and Follow-Up

  • Acknowledgment: Complaints are acknowledged within three business days of receipt.
  • Progress Updates: Whistleblowers receive regular updates on the status of their
    complaint, including any steps taken and the outcome.
  • Resolution: The resolution process aims to be completed within 45 days, with clear
    communication of findings.

6. Monitoring and Accountability

  • Oversight: The compliance team oversees the whistleblower process and regularly
    reviews policies to ensure they remain effective.
  • Feedback Mechanism: Whistleblowers may provide anonymous feedback on their
    experience to help Peppy Health improve its processes.

Conclusion

Peppy Health is committed to protecting those who speak up against unethical or unlawful
behavior. This policy ensures whistleblowers are supported, and all complaints are addressed
fairly, transparently, and without fear of reprisal.
For more information, contact the People Team at people@peppy.health