Whistleblower Policy Template

Introduction

The purpose of this whistleblower policy is to protect integrity and guarantee that any misconduct that is disclosed is dealt with quickly and efficiently. The company is dedicated to developing a culture of openness, moral conduct, and sound corporate governance in the face of a complicated and ever-changing commercial environment. There is a secure way for anyone to voice valid concerns about any misconduct in operations. The application of the COSO framework on complaints and whistle-blowing activities led to more organised and visible problems; therefore, effective corrective and preventive action may be conducted.

Parties To Be Eligible Whistleblowers

The following individuals are eligible to act as whistleblowers:

• Current or Former Directors and Company Secretaries: This includes those who currently hold or have previously held positions on the board of directors or served as company secretaries, offering them insight into the organization's governance and management.

• Current or Former Officers: This group consists of individuals who hold or have held executive roles within the organization, such as CEOs, CFOs, or other senior management positions, often providing them with access to critical and sensitive operational information.

• Current or Former Employees: Employees, whether full-time, part-time, or temporary, who are or were part of the organization, may have firsthand knowledge of unethical behavior or misconduct within the workplace.

• Current or Former Suppliers of Goods and Services: This includes individuals or organizations that provide goods or services to the business, whether compensated or not, as well as their employees who may observe improper practices in their interactions with the organization.

• Contractors and Their Employees (Paid or Unpaid): Individuals working as contractors, whether remunerated or voluntary, and their employees are also eligible. They might have valuable information about unethical or improper activities connected to the organization’s operations or partnerships.

Additionally, anyone who is a spouse, dependant, relative, or spouse of one of the individuals mentioned above is regarded as a "eligible whistleblower."

Disclosable Matters In Whistleblower Policy Template

What Constitutes a Disclosable Matter?

A disclosable matter refers to any information that:

• Highlights misconduct or an inappropriate state of affairs within the organization or any of its associated entities.

• Suggests that the organization, its related entities, or their officers and employees have engaged in activities that breach relevant laws or regulations.

• Represents a violation of any legislation that carries a penalty of imprisonment for 12 months or more.

• Poses a threat to public safety or the financial system's integrity.

Personal Work-Related Grievances

Personal work-related grievances are generally not protected under this Whistleblower Protection Policy unless they relate to broader misconduct or a breach of legal obligations regarding protection from detrimental treatment. These grievances typically include:

• Disputes or conflicts between employees.

• Decisions related to employment, such as transfers, promotions, or terminations.

• Disciplinary actions or issues regarding employment terms and conditions.

Such grievances should be managed through the organization’s established grievance resolution procedures instead of this Whistleblower Policy.

Reporting Mechanisms In Whistleblower Policy Template

Whistleblowers have access to multiple secure and confidential channels to report concerns or misconduct. These options include:

• Confidential Hotline: A 24/7 hotline dedicated to receiving anonymous reports. It provides a quick and convenient way for individuals to share concerns and receive immediate assistance from trained professionals.

• Email Reporting: Reports can be sent via email to [compliance@organization.com], allowing whistleblowers to provide detailed descriptions and attach any relevant supporting documents.

• Postal Reporting: For those who prefer a traditional approach, concerns can be submitted by mail to [Organization Address]. This method ensures that submissions are securely delivered and protects the anonymity of the whistleblower.

• Online Portal: A secure and easy-to-use platform designed for confidential reporting. It offers a straightforward way to submit concerns while maintaining the privacy of the whistleblower.

These channels are specifically designed to ensure safety and confidentiality, empowering whistleblowers to report issues without fear of exposure.

Malicious Complaints In Whistleblower Policy

The organization is committed to fostering a culture of transparency and accountability through its Whistleblower Policy. While it encourages individuals to report genuine concerns about misconduct, unethical behavior, or violations of regulations, it takes a firm stance against malicious or false complaints. A malicious complaint is defined as a deliberate attempt to provide misleading or untrue information with the intent to harm an individual, disrupt operations, or damage the organization’s reputation. Such actions undermine the integrity of the reporting process and can have serious consequences for all parties involved.

If a complaint is found to be knowingly false or malicious, the organization reserves the right to take appropriate disciplinary action against the individual responsible. This may include termination of employment or other legal measures, depending on the severity of the incident. The organization emphasizes that this policy is not intended to deter genuine whistleblowers but to ensure the reporting mechanism is used responsibly and ethically. All reports will be thoroughly investigated to distinguish genuine concerns from those made with malicious intent, ensuring fairness and maintaining trust in the whistleblower process.

Conclusion

The Whistleblower Policy underscores the organization's commitment to fostering an ethical, transparent, and accountable environment. By providing clear reporting channels and ensuring protection for whistleblowers, the policy aims to encourage individuals to come forward with genuine concerns without fear of retaliation. This framework not only supports compliance with legal and regulatory standards but also strengthens the organization's values and integrity. Regular reviews and updates to the policy will ensure its continued relevance and effectiveness, promoting a culture where ethical conduct is prioritized, and misconduct is addressed promptly and appropriately.