FREQUENTLY ASKED QUESTIONS

About EthicsPoint

    What is EthicsPoint?

    NAVEX provides Revolut with a confidential reporting tool called EthicsPoint. This tool allows employees to report potential, suspected, or actual misconduct, criminal offenses, and non-compliance with applicable laws, regulations, and internal policies, in line with Revolut’s Global Whistleblowing Policy.

    Why do we need a system like EthicsPoint?

    The Speak Up Portal, provided by NAVEX, is Revolut's primary whistleblowing channel. It is generally the easiest, fastest, and most secure way for employees to raise concerns confidentially and anonymously.

Reporting – General

    May I report using either the Internet or Mobile?

    Yes. EthicsPoint enables you to report confidentially and anonymously via the Internet or Mobile.

    Internet - revolut.ethicspoint.com.
    Mobile - revolutmobile.ethicspoint.com.

    What types of situations should I report?

    The EthicsPoint system allows employees to report concerns relating to:

    • A criminal offence that has, is being, or is likely to be committed;
    • A breach of legal obligation;
    • A danger to the health and safety of employees or others;
    • Breach of internal policies or procedures;
    • Behaviour or activity that harms the reputation or financial wellbeing of Revolut and/or its customers;
    • General malpractice i.e. immoral, illegal or unethical conduct;
    • Significant misconduct;
    • Concerns against a member of Senior Management;
    • Potential breach of the requirements in, or made under Regulations or Regulatory rules imposed by Regulatory bodies;
    • Breach of Revolut's Global Employee Handbook.

    If your concern relates to how you believe you have been treated at work or does not meet the threshold for a Whistleblowing investigation, this will be investigated under the HR Grievance process.

    Further details on the classification of concerns can be found via the Global Whistleblowing Policy or Global Whistleblowing Procedure.

    You can also find more details on the difference between HR Grievances and Whistleblowing here.

    If I see a violation, shouldn't I just report it to my manager and let them deal with it?

    Revolut encourages colleagues to feel empowered to speak directly with each other to solve problems, voice concerns or provide constructive feedback at all levels. In most cases, situations can be resolved through direct communication and feedback in a respectful and professional manner.

    However, if you feel uncomfortable raising something you see or hear whilst working at Revolut, whether in the office or remotely, there are multiple avenues for this to be raised. It is for such circumstances that we have partnered with NAVEX. We would rather you report anonymously than keep the information to yourself.

    Why should I report what I know?

    Revolut recognises that, by speaking up, employees play an important role in exposing wrongdoing that can harm Revolut, its customers and its reputation.

    We all have the right to work in a positive environment and with that right comes the responsibility of acting in an ethical manner and letting the appropriate people know if someone is not acting appropriately. By working together, we can maintain a healthy and productive working environment.

    Who can access these reports?

    All concerns are treated confidentially and are input directly into the EthicsPoint secure server. These reports are only accessible by the Whistleblowing team (Regulatory Response & Investigations team) and are managed and addressed internally by Revolut. While NAVEX provides the reporting system, they do not manage or action any submitted reports.

    What information should I include in my report?

    To enable a thorough investigation, you should include a detailed description. It's really important that as much detail is provided to assist the investigation. A good basis for the detail provided could include, but not limited to:

    • What happened;
    • When did it happen;
    • Where did it happen;
    • Who was involved;
    • How long has it been happening for;
    • How did you become aware?

    You do not have to have proof of your suspicions, but a report should always be submitted in good faith and with complete information.

    What happens after I submit my report?

    The Whistleblowing team will review the concern and determine the next steps after a report is submitted. If the issue is classified as whistleblowing, an investigation will be launched. All reports are confidential, and employees can choose to remain anonymous.

    When should I expect to hear back?

    The Whistleblowing team endeavors to review all reports within seven days of receipt and may contact you for further information or updates. While most whistleblowing investigations are completed within three months, some complex cases may take longer. You will be notified if an investigation exceeds three months.

    Can I seek external advice?

    Revolut employees are encouraged to raise any concerns they may have internally first by using the Speak Up Portal. For instances where it may be necessary, external reports can be made to regulatory bodies as listed in Revolut's Global Whistleblowing Policy.

Reporting Security & Confidentiality

    Can IT logs identify me as the person submitting a report?

    NAVEX does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to EthicsPoint is available.

    If you feel uncomfortable making a report from your work PC, you can use a PC outside of the work environment such as a personal laptop.

    I am concerned that the information I provide will reveal my identity. How can you assure me that will not happen?

    All concerns are handled confidentially, and where reported anonymously, the EthicsPoint system will not identify you as the reporter.

    If you decide to remain anonymous, you - as the reporter - should ensure that the body of the report does not reveal your identity by accident. For example, “On my desk next to Mr Smith…” or “In my 4 years at the company…”.

    What if I want to be identified with my report?

    Great, there is a section where you can provide personal information, such as your name and contact information. Please note, it is often easier to protect a reporter’s identity where it is known.

    What should I do if I believe I have been subjected to retaliation or victimised following a concern raised?

    If you believe you have been retaliated against as a result of raising a concern, you should notify the Whistleblowing team immediately or submit an additional report. Please provide as much detail as to why you believe you have been retaliated against, including any evidence.

    • Instances of retaliation may include, but not limited to:
    • Bullying, Harassment and/or Discrimination
    • Demotion or adjustment of duties
    • Dismissal and / or blacklisted from future employment
    • Denying employment benefits i.e. remuneration
    • Poor performance reviews (as a result of raising a whistleblowing concern and usually multi-pronged element to other retaliatory measures)
    • Blackmail, threats or criminal damage

    Retaliation usually occurs where behaviour/activity occurs after raising a Whistleblowing disclosure.

    My country is not listed. Why not?

    To maintain confidentiality and protect the identities of employees who wish to remain anonymous, we have disabled the ability to select reports from countries with fewer than 10 employees. In locations with small headcounts, individuals could be easily identified. For these locations, please select ‘Other’.

    Does the Whistleblowing team use artificial intelligence (AI)?

    The Whistleblowing team may use AI tools to aid and support the process of:

    • Reviewing and classifying concerns; and
    • Investigating concerns classified as whistleblowing, including but not limited to transcribing meeting notes of investigation interviews.

Tips & Best Practices

    I am aware of some individuals acting unethically, but it doesn't affect me. Why should I bother reporting it?

    Unethical behavior can negatively impact the company, our customers, and our employees.

    I am not sure if what I have observed or heard is a violation of company policy, or involves unethical conduct, but it just does not look right to me. What should I do?

    Submit a report. It's better to report a situation that may be harmless than to overlook potentially unethical behavior.

    What if my boss or other managers are involved in a violation? Won’t they get the report and start a cover-up?

    The EthicsPoint system and report distribution prevent implicated parties from being notified or accessing reports in which they have been named.

    What if I remember something important about the incident after I file the report? Or what if the company has further questions for me concerning my report?

    Upon submitting a report to EthicsPoint, you will receive a randomly generated "Report Key" and will be asked to create a password. This allows you to return to the system later to add details to your original report or respond to inquiries from the Whistleblowing team.

    Are these follow-ups on reports as secure as the first one?

    All communication will be treated with the same confidentiality as the original report, and anonymity will be maintained if the report was submitted anonymously.

    What if I lose my Report Key or forget the Password I created?

    If your report key or password is lost, you must submit a new report. Please state in the new report that it is connected to a previously submitted report or question. This process ensures that security and confidentiality are maintained.

    Can I still file a report if I don’t have access to the Internet?

    An EthicsPoint report can be filed from any computer with internet access, including from home.