Purpose
Provide accessible, confidential and protected channels for reporting suspected misconduct and ensure reports receive timely, fair and documented assessment.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Accept reports from all eligible persons | Employees, officers, directors, contractors, consultants, suppliers and other engaged third parties across all locations and jurisdictions in which the company operates. | Report intake |
| 2 | Accept internal and external reports | Internal reports through the Operational Manager, Human Resources Manager, or Board of Directors; recognize the right to report externally to the Centrale Bank of Curacao and St. Maarten (CBCS) where internal reporting is not feasible or appropriate. | Reporting record |
| 3 | Permit anonymous reporting | Advise that providing contact information may facilitate a more thorough investigation. Protect reporter identity to the extent possible, consistent with the need to conduct an adequate investigation and comply with legal obligations. | Anonymity acknowledgment |
| 4 | Record report and acknowledge receipt | Record the report in a restricted case file and acknowledge receipt within 5 business days when contact details are available. | Case file and acknowledgment |
| 5 | Conduct preliminary assessment | Determine the appropriate course of action, checking urgency, conflicts, retaliation risk, evidence-preservation needs and whether specialist or external support is required. | Preliminary assessment |
| 6 | Appoint investigator and initiate formal investigation | If warranted, ensuring impartiality and fairness; define scope, authority, confidentiality and reporting lines. | Investigation plan |
| 7 | Gather and preserve evidence | Interview relevant persons, maintain records of the investigation process and findings, and document outcomes fairly. | Evidence and findings record |
| 8 | Escalate legal or regulatory breaches | Escalate suspected legal or regulatory breaches and material risks to management, the Board, Legal or regulators as appropriate. | Escalation record |
| 9 | Communicate outcome and close case | Communicate the outcome to the whistleblower if contact information is provided, and to relevant stakeholders as appropriate; implement actions and close the case with retained evidence. | Case closure record |
| 10 | Monitor for retaliation | Monitor (including dismissal, demotion, harassment, or any adverse employment action) and investigate any suspected retaliatory action separately; any act of retaliation will result in disciplinary action, up to and including termination. | Retaliation monitoring record |
Exceptions and Escalation
Where a normal recipient is implicated or conflicted, the report shall bypass that person and go directly to an independent manager, the Board or an external authority. Deliberately false or malicious reports may be addressed under the disciplinary procedure after fair assessment.
Records
- Restricted report and acknowledgment
- Conflict and preliminary assessment
- Investigation plan, evidence and findings
- Outcome, escalation and remediation records
- Reporter communication and retaliation monitoring
Relationships
- Policy: POL-EMP-001 Employee Handbook
- Process: PRC-RSA-001 Resilience Systems and Assurance
- Control: CTRL-EMP-004 Ensure Whistleblower Reports Are Protected and Investigated
Assurance
Runtime effectiveness results are maintained in Odoo and assessed through the Hermes workflow tracked in ISS-HERMES-001. This note defines design, ownership, evidence expectations and testing method; it does not contain a manually maintained operation, evidence or overall effectiveness rating.
- Frequency: continuous and event-driven
History
- 2026-07-26: Created from section 6 of the approved Employee Handbook.