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Whistle-Blowing Policy

Introduction

This document presents FBDS’s Whistle-Blowing Policy (the “Policy”). It was prepared based on several similar documents publicly available combined with our own concerns.

Employees, collaborators, and subcontractors are often the first to realize that there may be something seriously wrong within an organisation. However, they may not express their concerns because they feel that speaking up would be disloyal to their colleagues or to the organisation. They may also fear harassment or victimization. In these circumstances, it may be easier to ignore the concern rather than report what may just be a suspicion of malpractice.

This policy aims at encouraging employees, collaborators, and subcontractors to feel confident in raising serious concerns and to protect them from possible internal reprisals or victimization if they have a reasonable belief that they have made any disclosure in good faith.

Reporting responsibility

We encourage employees, collaborators, and subcontractors to raise any serious concerns that they have about any aspect of service provision or the conduct of its board members, executives, employees, collaborators, and subcontractors of the organisation or others acting on behalf of the organisation.

Examples of concerns may be related to: fraud, corruption, bribery, unauthorized use of public funds of grants, blackmail, criminal offences and breach of law, endangering the heath or the safety of an individual, endangering the environment, sexual of physical abuse, unethical conduct, etc., for more information refer to FBDS’s Anti-Bribery and Corruption Policy.

Harassment or victimization

We as an organisation recognize that the decision to report a concern can be a difficult one to make. If what you are saying is true, you should have nothing to fear because you will be doing your duty to your employer, grantor, and those for whom you are providing the service.

The management will not tolerate any harassment or victimization (including informal pressures) and will take appropriate action to protect you when you raise a concern in good faith.

All concerns will be treated in confidence and every effort will be made not to reveal your identity if you so wish. At the appropriate time, however, you may need to come forward as a witness.

Anonymous complaints may be made through correspondence sent to the Chairman of the Board of Trustees and/or Vice-Chairman of the Board of Trustees and/or Executive Director, who will take the necessary measures to investigate the facts that have occurred.

Untrue allegations

If you make an allegation in good faith, but it is not confirmed by the investigation, no action will be taken against you. If, however, you make an allegation frivolously, maliciously or for personal gain, disciplinary action may be taken against you.

How to raise a concern

As a first step, you should normally raise concerns with your immediate manager. This depends, however, on the seriousness and sensitivity of the issues involved and who is suspected of the malpractice.

FBDS’s President of the Board of Trustees has overall responsibility for the maintenance and operation of this policy. He will maintain the records of concerns raised and the outcome and will report as necessary to the board.

If you do intend to raise the matter outside the Organisation, you should take into account the disclosure of confidential information.

Concerns may be raised verbally or in writing. Staff who wish to make a written report are invited to use the following format:

  • The background and history of the concern (giving relevant dates);
  • The reason why you are particularly concerned about the situation.

How will the organisation respond

The organisation will respond to your concerns. Do not forget that testing out your concerns is not the same as either accepting or rejecting them.

Where appropriate, the matters raised may:

  • be investigated by management, internal audit, Grievance Procedure disciplinary process;
  • be referred to an external auditor;
  • form the subject of an independent inquiry;
  • be referred to the police.