Introduction These terms and conditions shall govern your use of our website. By using our website, you accept these terms and conditions in full; accordingly, if you disagree with these terms and conditions or any part of these terms and conditions, you must not use our website. If you register with our website, submit any material to our website or use any of our website services, we will ask you to expressly agree to these terms and conditions. You must be at least 18 years of age to use our website; by using our website or agreeing to these terms and conditions, you warrant and represent to us that you are at least 18 years of age. Our website uses cookies; by using our website or agreeing to these terms and conditions, you consent to our use of cookies in accordance with the terms of our privacy policy. Copyright Notice Copyright © 2025 Ingham & Yorke Subject to the express provisions of these terms and conditions: we, together with our licensors, own and control all the copyright and other intellectual property rights in our website and the material on our website; and all the copyright and other intellectual property rights in our website and the material on our website are reserved. Permission to use website You may: view pages from our website in a web browser; download pages from our website for caching in a web browser; print pages from our website for your own personal and non-commercial use, providing that such printing is not systematic or excessive; stream audio and video files from our website using the media player on our website; and use our website services by means of a web browser, subject to the other provisions of these terms and conditions. Except as expressly permitted by Section 3.1 or the other provisions of these terms and conditions, you must not download any material from our website or save any such material to your computer. You may only use our website for your own personal and business purposes you must not use our website for any other purposes. Except as expressly permitted by these terms and conditions, you must not edit or otherwise modify any material on our website. Unless you own or control the relevant rights in the material, you must not: republish material from our website (including republication on another website); sell, rent or sub-license material from our website; show any material from our website in public; exploit material from our website for a commercial purpose; or redistribute material from our website. Notwithstanding Section 3.5, you may redistribute our newsletter in print and electronic form to any person. We reserve the right to suspend or restrict access to our website, to areas of our website and/or to functionality upon our website. We may, for example, suspend access to the website during server maintenance or when we update the website. You must not circumvent or bypass, or attempt to circumvent or bypass, any access restriction measures on the website. Accessing the Site Access to the site is granted on a temporary basis and is always subject to these terms and conditions. We reserve the right to modify or revoke access to the service without prior notice. You are responsible for securing access to the site and ensuring that anyone else using your internet connection is aware of and complies with these terms. We regularly update the site and may change the content at any time. If necessary, we may choose to suspend or permanently close the site. Intellectual Property You acknowledge and agree that all copyrights, trademarks, and other intellectual property rights related to the content available on this site remain solely with us or our licensors. You may use this material only as explicitly authorized by us or our licensors. Report Abuse If you learn of any unlawful material or activity on our website, or any material or activity that breaches these terms and conditions, please let us know. You can let us know about any such material or activity by email. Disclaimer Ingham & Yorke takes reasonable care to ensure that the information on this website is accurate; however, we cannot guarantee its accuracy and reserve the right to change the information, including these terms and conditions, at any time. You should check these terms and conditions for any updates each time you visit the site. Ingham & Yorke makes no representations or warranties regarding this website or its content, including text, graphics, advertisements, links, or other items. Additionally, neither Ingham & Yorke nor any contributors to this website provide any express or implied representations or warranties concerning the condition, quality, performance, accuracy, fitness for a particular purpose, completeness, or freedom from viruses of the content on this site. Furthermore, the content should not be considered financial advice. Trade Marks Our logos and our other registered and unregistered trade marks are trade marks belonging to us; we give no permission for the use of these trade marks, and such use may constitute an infringement of our rights. The third party registered and unregistered trade marks or service marks on our website are the property of their respective owners and, unless stated otherwise in these terms and conditions, we do not endorse and are not affiliated with any of the holders of any such rights and as such we cannot grant any licence to exercise such rights. Third Party Websites Our website includes hyperlinks to other websites owned and operated by third parties; such hyperlinks are not recommendations. We have no control over third party websites and their contents, and subject to Section 10.1 we accept no responsibility for them or for any loss or damage that may arise from your use of them. Variation We may revise these terms and conditions from time to time. The revised terms and conditions shall apply to the use of our website from the date of publication of the revised terms and conditions on the website, and you hereby waive any right you may otherwise have to be notified of, or to consent to, revisions of these terms and conditions. If you have given your express agreement to these terms and conditions, we will ask for your express agreement to any revision of these terms and conditions; and if you do not give your express agreement to the revised terms and conditions within such period as we may specify, we will disable or delete your account on the website, and you must stop using the website. Assignment You hereby agree that we may assign, transfer, sub-contract or otherwise deal with our rights and/or obligations under these terms and conditions. You may not without our prior written consent assign, transfer, sub-contract or otherwise deal with any of your rights and/or obligations under these terms and conditions. Severability If a provision of these terms and conditions is determined by any court or other competent authority to be unlawful and/or unenforceable, the other provisions will continue in effect. If any unlawful and/or unenforceable provision of these terms and conditions would be lawful or enforceable if part of it were deleted, that part will be deemed to be deleted, and the rest of the provision will continue in effect. Third Party Rights A contract under these terms and conditions is for our benefit and your benefit, and is not intended to benefit or be enforceable by any third party. The exercise of the parties’ rights under a contract under these terms and conditions is not subject to the consent of any third party. Entire Agreement Subject to Section these terms and conditions, together with our privacy and cookies policy, shall constitute the entire agreement between you and us in relation to your use of our website and shall supersede all previous agreements between you and us in relation to your use of our website. Law and Jurisdiction These terms and conditions shall be governed by and construed in accordance with English law. Any disputes relating to these terms and conditions shall be subject to the exclusive jurisdiction of the courts of England. Statutory and regulatory disclosures We are registered in the UK; you can find the online version of the register at www.companieshouse.co.uk, and our registration number is OC334579. Our VAT number is : 931 0996 20 Our Details This website is owned and operated by Ingham & Yorke. We are registered in England and Wales under registration number OC334579. Registered office is at Brookside Barn, Downham, Clitheroe, Lancashire, England, BB7 4BP You Can Contact Us by post, to the postal address given above; using our website contact form; by telephone, on the contact number published on our website

Introduction We are committed to safeguarding the privacy of our website visitors and service users. This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data. By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy. In this policy, “we”, “us” and “our” refer to Social Finance. For more information about us, see Section 18. How we use your personal data In this Section we have set out the general categories of personal data that we may process; in the case of personal data that we did not obtain directly from you, the source and specific categories of that data; the purposes for which we may process personal data; and the legal bases of the processing. We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services. We may process information contained in any enquiry you submit to us regarding services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent. We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others. We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks. In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. Please do not supply any other person’s personal data to us unless you have their permission to do so. Data We Collect At Ingham & Yorke, the data we typically collect includes the following: First Name, Middle Name, Surname, Previous Name, Date of Birth, Current Address, Residential Status, Previous Address, Landlord Details, Nationality, National Insurance Number, UK National Status, Doctor's Details, Number of Dependents, Dependents' Names, Dependents' Dates of Birth, Primary ID, Address ID, Bank Statements, Credit Card Statements, Mortgage Statements, Proof of Deposit, Payslips, Self-Employed Accounts, Employer's Name, Gender, Personal/Secure Loan Details, Personal Debit Details, Personal Expenditure, Existing Mortgage Details, Existing Insurance Details, Email Address, Phone Numbers, New Property Details, Solicitor Details, Estate or Letting Agents Details, New Mortgage Details, New Insurance Details, Criminal Offences/Convictions, IP Address, Cookies, Marital Status, Salary, Accountant Details, Previous Employers' Details, Employers' Address, Employers' Phone Number, Health, Ethnicity, Credit Card Details, Bank Details, Non-Resident Landlord Approval Numbers from HMRC, and Credit Search/Credit Score Details. Providing your personal data to others We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. Retaining and deleting personal data This Section 4 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. Purpose of Data Collection Evaluating applications for Ingham & Yorke products and services Conducting business and building relationships with Ingham & Yorke and its affiliates Processing payments and transactions, which includes: accounting, authorisation, clearing, chargebacks, auditing, billing, reconciliation, collections, handling complaints and inquiries, credit checks, and related dispute resolution activities Protecting against and preventing fraud, unauthorised transactions, money laundering (see below), tax evasion, claims, and other liabilities while managing risk exposure and ensuring agent quality, integrity, compliance, and security of business processes Creating and managing accounts, including associated authentication criteria (IDs and passwords) for your use with Ingham & Yorke Providing, administering, and communicating information about Ingham & Yorke products, services, offers, programs, and promotions, as well as their issuers, acquirers, and partners Compiling business directories, including contact information Operating, monitoring, evaluating, and improving our products, services, websites, mobile applications, and other digital assets Developing new products and services Managing communications and assessing the effectiveness and optimisation of advertising Ensuring the functionality of our website, mobile applications, and other digital assets Evaluating your interest in employment and reaching out to you regarding potential job opportunities Enforcing Ingham & Yorke's "Terms of Use" and other legal rights as required by applicable laws and regulations, or as requested by any judicial process or governmental agency with jurisdiction over Ingham & Yorke or its affiliates Complying with industry standards and Ingham & Yorke's own standards. Security of personal data We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data. We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems. Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology. You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet. Amendments We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy. We will not notify you of changes to this policy. Your rights In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights. Your principal rights under data protection law are: the right to access; the right to rectification; the right to erasure; the right to restrict processing; the right to object to processing; the right to data portability; the right to complain to a supervisory authority; and the right to withdraw consent. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest. To the extent that the legal basis for our processing of your personal data is: (a) consent; or (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal. You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 7. Third party websites Our website includes hyperlinks to, and details of, third party websites. We have no control over, and are not responsible for, the privacy policies and practices of third parties. Personal data of children Our website and services are targeted at persons over the age of 18. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data. Updating information Please let us know if the personal information that we hold about you needs to be corrected or updated. Acting as a data processor In respect of personal identifiable data, we do not act as a data controller; instead, we act as a data processor. Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.

About cookies A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. Cookies that we use We use cookies for the following purposes: analysis – we use cookies to help us to analyse the use and performance of our website and services advertising - we use cookies to help us to display advertisements that will be relevant to you Cookies used by our service providers Our service providers use cookies and those cookies may be stored on your computer when you visit our website. We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Disable Cookies This depends on which cookies you disable, but generally, the site may not function properly if cookies are turned off. If you only disable third-party cookies, you will still be able to view the site. However, if you disable all cookies, you will not be able to perform a search on this site. Managing cookies Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links: Chrome Firefox Opera Internet Explorer Safari Edge Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, this will not impact usability of the features on our website.

Our Details This website is owned and operated by Ingham & Yorke. We are registered in England and Wales under registration number OC334579. Registered office is at Brookside Barn, Downham, Clitheroe, Lancashire, England, BB7 4BP You Can Contact Us by post, to the postal address given above; using our website contact form; by telephone, on the contact number published on our website

This procedure applies to all employees Should you have any queries, please contact Helen Vickery or Thomas Manson. Section One: Overview The purpose of this document is to set out Ingham and Yorke’s Client Money Handling procedures, both internal controls and procedures. The procedures have been set out in accordance with best practice and RICS regulation. This document should be read in conjunction with the RICS Professional Standards and Guidance UK, Client Money Handling, 1st Edition. DEFINITION OF CLIENT MONEY: MONEY OF ANY CURRENCY (WHETHER IN THE FORM OF CASH, CHEQUE, DRAFT OR ELECTRONIC TRANSFER) THAT: AN RICS REGULATED FIRM HOLDS FOR OR RECEIVES ON BEHALF OF ANOTHER PERSON, INCLUDING MONEY HELD BY A REGULATED FIRM AS STAKEHOLDER; AND IS NOT IMMEDIATELY DUE AND PAYABLE ON DEMAND TO THE RICS REGULATED FIRM FOR ITS OWN ACCOUNT; BUT EXCLUDING FEES PAID IN ADVANCE FOR PROFESSIONAL WORK AGREED TO BE PERFORMED, AND CLEARLY IDENTIFIABLE AS SUCH, UNLESS THE FEES ARE FOR WORKS UNDERTAKEN AS A PROPERTY AGENT AS DEFINED BY THE RULES OF THE RICS CLIENT MONEY PROTECTION SCHEME FOR PROPERTY AGENTS. [RICS CLIENT MONEY HANDLING 1 ST EDITION, OCTOBER 2019] Section Two: How and when client money is held All client money held or received by Ingham and Yorke is banked into either: A general client bank account – a client bank account which holds pooled client money for multiple clients; A designated discrete bank account – set up to hold client money for a single client. The name of the client will be incorporated into the account name. A client may request that tenants pay monies directly to a bank account by themselves where Ingham and Yorke will have no control over these accounts. These accounts are not covered by the RICS client money protection scheme. In the cases of both A & B, the client money is under the exclusive control of Ingham and Yorke and the bank accounts are held by Barclays Bank who are regulated but the Bank of England and Financial Conduct Authority. All client money held is available on demand. Section Three: Access to funds Ingham and Yorke equity partners have full access to client account funds, as per the bank mandates. Employees in the roles of book-keepers and account personnel have access via the Barclays.net portal with permissions set up for their individual log-in: Bookkeepers / Accounts personnel have the ability to view bank statements and upload payments for authorisation. Equity Partners are responsible for authorising bank payments, including changes to standing orders. For payment via cheques one partner can sign a cheque. Changes to bank mandates require the signatures as per the bank mandate. Section Four: Timescale for receipting of cash and cheques into a client account The book-keepers at Ingham and Yorke log all monies received via the post or hand-delivered to the office on the day of receipt, where possible, and allocate to the appropriate client ledgers. All cheques are banked promptly either at Barclays Bank or Post Office, usually within 48 hours of receipt. Cheques are stored securely in the relevant office where they are received in a fire-proof safe or lock box until they are banked. Any unidentified funds are investigated as soon as possible. If it is not possible to identify what the money relates to it will be returned to the sender within one month of receipt. Section Four: Authorisation of payments from a client account As noted in Section Two, access to bank accounts is limited to appropriate and authourised individuals. All payments are made via electronic transfer (BACS or CHAPS) wherever possible, but in all cases of payment, the payment request must be supported by appropriate evidence (such as the original invoice). No payments are made unless there are sufficient funds held in the relevant account to cover the payment. All payments from a client account require approval prior to payment in line with individual client instructions. For the payment of purchase invoices, they are approved internally by the partner who oversees the client, once approved they are logged onto Barclays.net by a book-keeper, as identified in section 2. An equity partner then checks the details and approves for payment. Once the payment has been authorised, the book-keeper then logs the bank transaction number on the payment. Section Five: How interest and bank charges are handled Ingham and Yorke’s general client accounts are interest bearing with interest being held in those accounts. On discrete bank accounts, the interest is retained by the client within those accounts. Neither general nor discrete accounts have any bank charges (maintenance and transactional banking costs). Section Six: Bank reconciliation procedure Records are maintained for all general and discrete accounts, including an audit trail of transactions for each amount. Bank reconciliations are performed on a monthly basis for all accounts. As per the RICS regulations, a three-way reconciliation is completed between the bank statement, general ledger and individual client ledger cashbooks for the general client accounts. All bank reconciliations are reviewed by two authorised parties; one of which will be the book-keeper who completed the reconciliations, the other a Partner. Section Seven: Providing information to clients about monies held on their accounts As part of agreeing our responsibilities with our clients at the outset of an instruction, we set out the details of the financial information and frequency with which it is to be provided to our clients and this is documented through an engagement letter or property management agreement. It is our normal practice to provide client money information to a client at a monthly or quarterly frequency.

QA09: COMPLAINT HANDLING PROCEDURE A copy of this note should be given to any person making a complaint against the practice or if otherwise requested. This note sets out the procedure which Ingham & Yorke LLP will follow in dealing with a complaint. A person has been appointed in each of our offices to deal with complaints, and you should not hesitate to contact the relevant person. Details are as set out below: - Miss H.J Vickery in respect of the Huntroyde Estate Office, Padiham, Burnley, Lancashire, BB12 7QX – Telephone: 01282 771024. Email: hvickery@inghamandyorke.co.uk Mr. C.S.E. Yorke in respect of the Brookside Barn, Downham, Clitheroe, Lancashire, BB7 4BP – Telephone: 01200 423655. Email: cyorke@inghamandyorke.co.uk Where your complaint is initially made verbally, you will be requested to send a written summary of your complaint to the person dealing with it. Once we have received your written summary of the complaint, we will contact you in writing within seven days to inform you of our understanding of the circumstances leading to your complaint. You will be invited to make any comments that you may have in relation to this. Within twenty-one days of receipt of your written summary, the person dealing with your complaint will write to you, in order to inform you of the outcome of the investigation into your complaint and to let you know what actions have been or will be taken. If you remain dissatisfied with any aspect of our handling of your complaint, then we will attempt to resolve this promptly through negotiations, and otherwise if the complaint has still not been resolved to your satisfaction, we agree to the referral of your complaint to either: i. The Ombudsman Services: (in the event of you being a consumer being broadly defined as a person who is not acting in the course of any business) Ombudsman Services: Property PO Box 1021, Warrington, WA4 9FE T: 0333 440 1634 or 01925 530270 E: enquires@os-property.org W: www.os-property.org ii. Property Redress Scheme Property Redress Scheme: Limelight, 1st Floor Studio 3, Elstree Way, Borehamwood, Hertfordshire, WD6 1JH T: 0333 321 9418 E: info@theprs.co.uk W: www.theprs.co.uk

This procedure applies to all employees. Should you have any queries, please contact Helen Vickery or Thomas Manson. Section One: Overview Ingham & Yorke is committed to maintaining high ethical standards with a culture of openness and accountability in all its business dealings to ensure that fraud, illegal, and unethical conduct and wrongdoing are exposed and remedied. Ingham & Yorke takes any suspected malpractice such as fraud, illegal or unethical conduct or wrongdoing with the utmost seriousness. It is recognised that employees are often the first to become aware when someone connected with the firm is engaged in misconduct or malpractice. In such circumstances, Ingham & Yorke encourages employees to speak-up and raise any such concerns with senior management at the earliest opportunity. Any attempt to victimise an employee for having raised a legitimate concern or to deter anyone from raising such a concern is a serious disciplinary offence. This policy is not intended to and does not apply to Client complaints relating to possible malpractice and/or misconduct, which should be raised with line with the firm’s Complaints Handling Procedure. If in doubt about this, please consult one of the Partners. This policy does not apply to personal grievances such as alleged bullying, harassment or issues relating to terms of employment. Any such issues should be raised with one of the Partners. Section Two: What activities are covered The following activities are considered by the firm to constitute misconduct or malpractice and are covered by this procedure: Fraudulent activity (financial or other) Criminal offences (excluding minor road traffic offenses) Failure to comply with any legal duty A miscarriage of justice Offering or accepting bribes (defined by the UK Bribery Act 2010, Foreign Corrupt Payments ACT 1977, or similar). A health and safety risk An environmental risk Deliberate concealment of any of the above. This list is not exhaustive, and the firm values any report that is made which could be reasonably considered to be in the public interest. It is not necessary for you to have proof that the alleged malpractice or misconduct is being or is likely to be committed – reasonable suspicion is sufficient. An instruction to cover up is in itself a disciplinary offence. If you are instructed to remain silent, even if this person is in authority, you should not agree and you should raise your concern to a higher level of management. You should note however that any false report which is made maliciously or for personal gain may lead to disciplinary action. When you report alleged malpractice or misconduct under this procedure you have the right not to be dismissed or be subjected to victimisation, including detriment, bullying or harassment from another employee. Section Three: Procedure Report any alleged suspicious activities promptly Do not leave it until it is too late Reports can be made on the basis of a suspicion – you do not have to be in possession of hard facts. There is no need for you to undertake any investigations. Contact: Depending on the seriousness of the malpractice and who you think is involved you can address your report to any of the following: contacting the ‘speak-up’ line which is independently overseen by Safecall. You can call Safecall on 0800 915 1571 at any time. Alternatively, Safecall can be contacted via www.safecall.co.uk/report any of the Partners. Form of report: The report can be made orally, or in writing. If you choose to make a report orally, you can bring a colleague or accredited union representative with you if you wish. If you wish to raise the matter in confidence you should make this clear when you make the report. Anonymous reporting: You can make a report anonymously but it is then much harder to investigate and it is therefore best to declare your identity. Your identity will not be disclosed without your prior consent save where required by legal or regulatory process. Confidentiality: If you make an allegation in the reasonable belief that it is in the public interest, every effort will be made to protect you and your identity even if the allegation is later proven to be untrue. Investigation: If, after preliminary enquiries have been made, a full investigation is necessary then the firm will either investigate internally or refer it to an appropriate external organisation. The investigation may involve you and other individuals given written statements and commenting on additional evidence gathered. Acknowledgement and Outcome: The firm will aim to acknowledge receipt of your report within ten working days and will advise you of the outcome of the investigation, subject to any legal constraints.