Whistleblower Policy

Purpose:

The purpose of this whistleblower policy is to encourage and enable employees, partners, suppliers, customers, and other stakeholders to raise concerns about potential illegal, unethical, or improper conduct within our business. This policy aims to ensure transparency, accountability, and the protection of whistleblowers from retaliation.

Scope:

This policy applies to all employees, contractors, suppliers, partners, and stakeholders associated with our company.

Policy:

Reporting Procedure:

• • • Any individual who becomes aware of or suspects unethical, illegal, or improper conduct within the company is encouraged to report it promptly.
    • Reports can be made verbally or in writing to any of the following individuals or departments:
      • Immediate supervisor or manager
      • Human Resources department
      • Compliance department
      • Legal department
      • CEO or top management
    • Reports should include as much detail as possible, including the nature of the concern, individuals involved (if known), dates, times, and any supporting evidence.

Confidentiality:

• • • • Reports of potential misconduct will be treated confidentially to the extent possible, consistent with the need to conduct a thorough investigation.
      • Whistleblowers’ identities will be protected to the fullest extent permitted by law and will not be disclosed without their consent unless required by law or necessary for the investigation.

Non-Retaliation:

• • • Our company prohibits retaliation against individuals who make good faith reports of misconduct. Retaliation includes, but is not limited to, termination, demotion, harassment, or any adverse action.
    • Any retaliation against a whistleblower will result in disciplinary action, up to and including termination of employment or business relationship.

Investigation Process:

• • • Upon receiving a report, the designated authority (e.g., Compliance, HR, Legal) will promptly investigate the allegations in a fair and impartial manner.
    • Investigations will be conducted discreetly, and only those individuals directly involved or necessary to the investigation will be informed.

Disciplinary Action:

• • • If an investigation substantiates the allegations of misconduct, appropriate disciplinary action will be taken against the individuals involved, up to and including termination of employment or business relationship.
    • Disciplinary actions will be determined on a case-by-case basis, considering the severity of the misconduct and any mitigating factors.

Record Keeping:

• • • Records of all whistleblower reports and investigations will be maintained confidentially and securely.

Compliance:

All employees, contractors, suppliers, partners, and stakeholders are expected to comply with this whistleblower policy. Failure to comply may result in disciplinary action.

Review and Amendment:

This policy will be reviewed periodically to ensure its effectiveness and compliance with applicable laws and regulations. Amendments may be made as necessary.

Acknowledgment:

All employees, contractors, suppliers, partners, and stakeholders are required to acknowledge receipt and understanding of this whistleblower policy upon initial employment or engagement and periodically thereafter.

Conclusion:

This whistleblower policy demonstrates our commitment to maintaining a culture of integrity, transparency, and accountability within our company. We encourage open communication and reporting of concerns to ensure the ethical conduct of our operations.