Whistleblowing Policy

1. Purpose

This policy sets out how anyone — including freelancers, contractors, commercial counterparties or members of the public — can raise genuine concerns about wrongdoing connected to SuperSubBetting.

2. Legal context

Legal requirement: The statutory whistleblower-protection regime under the Public Interest Disclosure Act 1998 (PIDA) protects employees and workers who make qualifying disclosures. SuperSubBetting has no employees and is therefore not subject to PIDA as an employer. However, this policy reflects the spirit of PIDA and provides a clear escalation route for any concern raised.

Why this policy still exists: A documented route helps contractors, counterparties and readers raise concerns clearly and safely.

3. Scope

This policy applies to:

• Any freelancer or contractor engaged by SuperSubBetting.
• Operators or other commercial contacts with a concern about the business's conduct.
• Any member of the public who has a genuine concern about SuperSubBetting's activities.

4. What kinds of concern are covered

• Suspected fraud, financial crime or dishonest conduct.
• Breach of a legal or regulatory obligation.
• Publication of misleading, false or harmful content.
• Breach of data protection obligations.
• Bribery or corruption.
• Modern slavery or labour exploitation.
• Any other matter that may cause harm to individuals or damage to legal or ethical standards.

This policy does not cover personal grievances unrelated to wrongdoing, such as ordinary contract disputes. Those should be raised directly as a commercial matter.

5. How to raise a concern

1. Contact the sole trader directly: Email info@supersubbetting.com with a clear description of the concern, the date(s) involved and any supporting evidence. You may raise concerns anonymously, though providing contact details allows for a fuller response.
2. If the concern is about the sole trader personally, or you do not feel able to contact the business directly: Report to the relevant external authority (see below).

6. External escalation routes

• Data protection concerns: Information Commissioner's Office (ICO) — ico.org.uk
• Financial crime / fraud concerns: Action Fraud — actionfraud.police.uk / 0300 123 2040
• Gambling-related operator concerns: UK Gambling Commission — gamblingcommission.gov.uk (note: SuperSubBetting is not a licensed operator; concerns about operator conduct should be directed to the UKGC directly)
• Tax fraud: HMRC — gov.uk/report-tax-fraud
• Modern slavery: Modern Slavery Helpline — 0800 0121 700

7. No detriment

SuperSubBetting will not take any adverse commercial action against any person for raising a genuine concern in good faith, even if that concern turns out to be unfounded.

8. Record-keeping

All concerns received are logged with the date, nature of the concern and the action taken. Records are retained for six years.

9. Response timeframe

The sole trader will acknowledge receipt of a concern within five working days and provide a substantive response within 28 calendar days where possible. If the matter is referred to an external authority, the referral will be confirmed to the reporter (unless the reporter is anonymous).