// COMPLIANCE · WHISTLEBLOWING CHANNEL

Report a concern.
Confidentially.

If you have witnessed or have reasonable grounds to suspect a serious wrongdoing inside Scout, or by someone acting on Scout's behalf, this page is how you raise it. Reports are handled by a restricted, designated team. Reprisals against reporters are prohibited.

CHANNELwhistleblowing@scoutgaminggroup.com
SCOPESerious wrongdoing, misconduct, breaches of law or internal policy
HANDLED BYDesignated whistleblowing handlers (Compliance)
ACKWithin 7 days, where contact details are provided
FOLLOW-UPWithin 3 months
CONTROLLERSScout Ltd · Scout & Co Limited (Malta)
// IMMEDIATE RISK If a report concerns an imminent risk to life, safety or critical infrastructure, do not wait for our internal process. Contact local emergency services (in the EU: 112) and competent authorities directly. This channel is for non-emergency reports of wrongdoing.
// 01 · WHAT TO REPORT

What this channel is for.

Use this channel to report a serious concern related to Scout's business, employees, contractors, suppliers or partners. Examples include, but are not limited to:

  • Fraud, corruption, bribery or money laundering
  • Breaches of gambling, financial or data-protection law
  • Material breach of internal policies (Code of Conduct, Information Security, Supplier Security)
  • Discrimination, harassment, or threats
  • Health and safety risks
  • Attempts to obstruct or retaliate against a report

If the concern is a routine HR matter, please raise it with your manager or People & Culture first. This channel is for serious wrongdoing that justifies a confidential process.

// 02 · HOW IT IS HANDLED

Who reads your report.

Reports arrive in a restricted-access inbox monitored only by designated whistleblowing handlers within Compliance. The handlers are bound by confidentiality and operate independently of any business line that could be implicated by a report. Where a handler has a conflict of interest with the subject of the report, a substitute handler is appointed.

Your identity, and any information that could reveal your identity, is shared only with the people necessary to assess and act on the report, and on a strict need-to-know basis.

// 03 · ACKNOWLEDGEMENT & FOLLOW-UP

Timelines.

// 03.1 · ACKNOWLEDGEMENT
Within 7 days
Where you have provided contact details, we acknowledge receipt of your report within seven (7) days.
// 03.2 · FOLLOW-UP
Within 3 months
We provide feedback on the assessment, planned actions and outcome where you have not requested otherwise, within three (3) months.
// 04 · WAYS TO REPORT

You can report in writing, anonymously, or in person.

// 04.1 · WRITTEN · DEFAULT

Email the dedicated channel.

Send your report to the dedicated whistleblowing address. The inbox is restricted to designated handlers and is not visible to other Scout staff. Include as much detail as you can, but do not include information you do not need to include.

// 04.2 · ANONYMOUS

You may submit anonymously.

Anonymous reports are accepted and will be assessed in the same way as identified reports, where the information provided is sufficient to do so. If you wish to remain anonymous, do not include personal information in the report.

Note: an anonymous report limits our ability to confirm receipt and to come back to you with follow-up. Where you can be reached, even via a pseudonymous account, please indicate that in the message.

// 04.3 · ORAL · ON REQUEST

Oral and in-person reporting.

You can request to report orally — by telephone or in a confidential meeting — at your reasonable request. To arrange this, email the channel and ask for an oral intake. We will arrange a meeting within a reasonable time and document the report with you.

// 04.4 · EXTERNAL

External authorities.

You have the right to report directly to a competent external authority instead of, or in addition to, using this channel. Depending on the subject matter, this may include national whistleblowing authorities, data-protection regulators, gambling regulators (e.g. the Malta Gaming Authority, the UK Gambling Commission), law enforcement, or other competent bodies in your jurisdiction. Using this channel does not waive that right.

// 05 · PROTECTION AGAINST REPRISALS

You are protected.

Scout prohibits retaliation against any person who, in good faith, makes a report through this channel, supports a reporter, or participates in a follow-up investigation. Reprisal — including dismissal, demotion, harassment, exclusion, withholding of work, or any other detrimental treatment — is a serious breach of Scout's Code of Conduct and is itself a reportable matter through this channel.

Good-faith reporting does not need to be correct to be protected: what is required is that you had reasonable grounds to believe the information was true at the time of reporting.

// 06 · WHAT WE WILL NOT DO

Limits we keep.

  • We will not seek to identify anonymous reporters.
  • We will not disclose your identity, or information that could reveal it, except to the people necessary to assess and act on the report — and only on a need-to-know basis.
  • We will not store report content in logs, email subject lines or ticketing systems where access cannot be restricted to handlers.
  • We will not use information from this channel for any purpose other than handling the report (and meeting our legal obligations).
// 07 · DATA & PRIVACY

How your data is processed.

Personal data submitted through this channel is processed under separate terms set out in the Whistleblowing Privacy Notice. The notice covers the controllers, the types of data processed, legal bases, retention periods, transfers, and your data-subject rights. Please read it before submitting a report that contains personal data.