Whistleblower procedure

1. Acknowledgement

Immediately acknowledge the complaint, while maintaining confidentiality. Assure the whistleblower that their identity and information will be kept as confidential as possible throughout the investigation. Do not confirm or deny specific details or make promises about the outcome. 

2. Initial review

Review the complaint, identify the parties involved, the specific actions or events, and any potential evidence mentioned. 

Determine the scope: Is the complaint related to illegal activity, a violation of company policy, or an ethical concern?

Inform the appropriate personnel, such as legal team (compliance), human resources, or a designated BoD member.

Do not share the information with anyone else who is not directly involved in the review.

3. Investigation

Assign the investigation to an impartial party (BoD member). 

Create a clear investigation plan that outlines the objectives, timeline, list of potential witnesses, and the types of evidence to be gathered. Secure evidence by uploading relevant material to a designated restricted folder. 

• Conduct confidential interviews with the whistleblower, the subject of the complaint, and any other relevant witnesses. 

• Collect and review all relevant documents and data. 

• Test affected systems and procedures.

• Evaluate the credibility of the information provided by all parties involved.

4. Documentation 

Prepare a comprehensive report of the findings. The report should summarise:

• timeline,

• the allegations, 

• the investigation steps, 

• the evidence gathered, 

• conclusions reached.

5. Outcomes 

Based on the findings, decide on the appropriate action. This could include policy changes, training, report to relevant external authorities or no further action if the allegations are unsubstantiated. If possible, inform the whistleblower that the investigation has been completed and that appropriate action has been taken, without disclosing confidential details.

5. Final steps

Ensure the whistleblower is protected from any form of retaliation. This is a critical legal and ethical obligation. If systemic issues are identified, implement new controls, policies, or training to prevent future occurrences. Evaluate the effectiveness of the whistleblower complaint procedure and make improvements as needed.

Created by: Compliance Manager

Creation date: 03.09.2025

Last modified: 27.11.2025

Document approver: Head of Compliance