Direct Honest Safe International Exchange FZE
The Company shall be committed towards adhering to the highest standards of governance, openness, transparency, honesty, integrity, accountability and ethical, moral & legal conduct of business operations. The Company shall create an open, transparent and a safe working environment where its staff shall be encouraged to report any irregularities within the Company, in good faith.
The Whistleblowing right is granted to a staff to speak out when he or she believes that there are good reasons to believe that an instruction received, an operation being studied or, more generally, a situation has arisen that is not compliant with the rules governing the Company.
All Company staff may exercise their right to whistleblowing in relation to actions they become aware of, either directly or indirectly, in the course of their professional duties. This right must be exercised responsibly and not be misused for purposes of defamation, denigration, or vilification. Any reports received will be investigated confidentially by the designated recipient.
a) The Whistleblowing Policy ("Policy") aims to enable the Company's staff to report the following incidents:
b) This Policy provides for:
a) This Policy is applicable to the Company's Board, Senior Management team, and all its staff (including contractual and seconded staff).
b) This Policy applies exclusively to events and individuals that may cause harm to the Company's staff, the Company itself, or its reputation, and does not extend protections to the Whistleblower personally. Accordingly, any complaints or grievances falling outside this scope shall not be addressed under this Policy.
This Policy was prepared for the purpose of license application. The content of this Policy may be updated to address the business and regulatory requirements as and when they become available, during the implementation phase of the Company, prior to the launch of the business.
The Whistleblowing Policy of the Company shall be based on the following principles:
All staff shall demonstrate honesty, transparency, integrity, and due care in fulfilling their responsibilities.
The Company encourages staff to report suspected or actual wrongful conduct in good faith.
Sensitivity, discretion, and confidentiality will be given to whistleblowing reports.
Any form of retaliation against Whistleblowers is strictly prohibited.
A 'Whistle-blower' shall report any reasonable concern, including but not limited to the events captured in Section 1 of this Policy.
The Company shall set up a dedicated email account to enable the reporting of whistleblowing cases.
The Compliance Function shall undertake the responsibility of managing the account as well as communicating the use of this account to all stakeholders of the Company.
In case the concern is against a Compliance staff, Whistle-blower shall directly send an email to the Chief Internal Audit Officer.
The report shall contain sufficient information to substantiate the concern and to enable a smooth investigation process.
The Compliance Function shall perform an initial review and route the concerns to the relevant stakeholders (Case Manager).
In all cases, a Whistle-blower has the full freedom to report any incident to VARA directly.
Whistleblowing investigations shall be managed by the stakeholders, also called Case Manager, mentioned in Section 3 of this Policy.
In dealing with suspected misconduct, reasonable care will be taken to avoid baseless allegations, premature notice to persons suspected of misconduct, and disclosure of suspected misconduct to persons not involved with the investigation.
Staff are required to cooperate fully in any official investigation, audit, or similar request.
The investigation process may include meetings with the staff member to discuss the reported concerns. While absolute proof of wrongdoing is not required, the staff member must present reasonable grounds supporting their concerns.
The Case Manager will keep the Whistleblower informed about the status of the reported concern and the approach taken to address it. However, a balance will be maintained between the Whistleblower's legitimate interest in receiving updates and the need to preserve the confidentiality of the investigation process.
If the allegation does not have sufficient evidence or merit, the allegation shall be dismissed. The Whistleblower shall be informed in cases of dismissal and the rationale for dismissal shall be documented for data retention and audit trail.
The investigations shall be conducted within (10) working days from the date of the concern being raised. The timeline may vary depending on the nature of the case being considered.
The Compliance Officer shall oversee the management of all Whistleblowing cases.
The Compliance Officer shall be responsible for providing all investigation recommendations, unless the concern raised is against a Compliance staff, in which case, the Chief Internal Audit Officer shall be responsible for providing the recommendations.
The Human Resources representative shall undertake disciplinary actions against the person being investigated if the allegation is found to be true and valid.
The Compliance Function shall maintain a record of all Whistleblowing cases including those that were dismissed for reporting purposes. They shall exercise due diligence to ensure the accuracy of the reporting by providing all necessary details related to the case reported and attaching all documents evidencing the whistleblowing case.
The Compliance Officer shall be responsible for the reporting of whistleblowing cases (including dismissed cases) to the CEO on a periodical basis.
Summary details and statistical information and data relating to the types of reports received and corrective measures taken shall be maintained for a minimum of 5 years from the closing of the investigation, except stated otherwise by the local law.
Any retaliation, including but not limited to threat of physical harm, loss of job, punitive work assignments, or reduced salary or wages, will be promptly investigated by the 'Working Group'.
The Company will do its best to protect the identity of the whistle-blower. It must be appreciated that the investigation process may reveal the source of the information.
The Company encourages a Whistle-blower to disclose his/ her name in reporting the allegation. Concerns expressed anonymously are much less powerful but will nevertheless be considered.
The Company's staff shall receive training with respect to Whistleblowing as part of the annual mandatory learning modules.
A culture of awareness shall be established across the Company, through periodic communications to all staff via email or verbal communications, flyers/posters, screen displays, and other means, as deemed appropriate by the Company.
All reports will be treated with strict confidentiality.
