Whistleblowing Procedure

27th November 2024

The purpose of the whistleblowing procedure is to enable suspected incidents or incidents of business wrongdoing to be raised safely within the company, handled adequately and allow for proper investigation and handling in a timely manner.

Reporting Responsibility

Every individual has the responsibility to report any business wrongdoing.

This procedure relates to 

  • All forms of financial malpractices or impropriety such as fraud, corruption, bribery, theft and concealment.
  • Failure to comply with legal obligations, statutes and regulatory directives.
  • A breach of the Company’s Anti-Bribery Policy.
  • A Breach of the poa! Code of Business Conduct.
  • A breach, or potential breach of health and safety policy or legislation.
  • Connected transactions not disclosed or reported in line with regulations.
  • Non-disclosure of conflict of interest.
  • Harassment of a colleague, customer or other individual.
  • Damage to the environment.
  • The committing of a criminal offence.
  • Attempt to conceal any of the above listed acts.

The Whistleblowing Procedure should be read in conjunction with the other guidelines that Poa! Internet has, including the Partner Code of Conduct and our internal HR manual. This procedure applies to Poa! Internet employees, as well as our business partners (third parties). 

Reporting in Good faith

Anyone reporting a concern must do it in good faith. The act of making allegations that prove to be unsubstantiated, and that prove to have been made maliciously, recklessly, with gross negligence, or with the foreknowledge that the allegations are false, will be viewed as a serious disciplinary offense and may result in disciplinary action being taken against you.

Protection

Any person who acts in good faith and submits a Report concerning a Suspicion of Business Wrongdoing or a Suspicion of an Incident will not encounter any form of harassment or unfair treatment in his/her position within our company because of the fact that he/she has submitted a Report.

In the event that a reporter believes that they are being victimised or subjected to a detriment by any person within the company as a result of reporting a concern or assisting the company in any investigation under this policy they must inform our Chief Operating Officer.

Reporting procedure

This procedure will work for both internal employees and external third parties. External parties include but not limited to contractors, consultants and suppliers.

Step 1: Report the concern

As soon as you are aware of any wrongdoing, report the issue to

  • Your line manager/direct supervisor,  or/
  • Your head of human resources department, or /
  • Your head of operations.

It is important to first try and report the issue internally, and hopefully resolve before engaging with outside parties.

  1. In situations where you feel uncomfortable in approaching these people, as you feel that they may not manage your issue appropriately or this would serve no purpose, then feel free to engage with:
  • Your contact person at Poa! Internet
  • Chief operations officer
  1. When all other options are exhausted, or when the the above reporting options are not possible due to various circumstances, please send an email whistleblower@poainternet.net 

The reports sent here will be treated with the highest level of confidentiality and anonymity. It will be handled by a member of the board that is not part of the leadership team of the company. Therefore, this option only is to be used when every other option is exhausted.

When raising your concern, we kindly request that you provide the below information, so as to facilitate the investigation:

  • Outline of the known or suspected wrongdoing;  
  • Details, to the best of your knowledge, about when, where and how it occurred;  
  • A list of the names of those suspected of being involved (both internally and externally);  
  • A list of the names of anyone who may have relevant information;  
  • Details of how you came to know about the suspected activities; 
  • What, if any, breaches of internal controls, policy, procedure or other requirements you believe took place;  
  • Any specific recommendations you have for actions;  
  • Your name and contact details. Please note – these will be kept confidential as far as is reasonably practicable; 
  • Date and time of making the report.
Step 2: Acknowledgement of receipt of concern

When the concern has been brought to our attention, we will acknowledge receipt of your concern within 2 working days.

Step 3: Investigation of reported concern/complaint

An investigation will be conducted as speedily and sensitively as possible in accordance with all relevant laws and regulations. If appropriate, you will be regularly informed on the progress of these investigations and any action to be taken.

As far as reasonably practicable, the confidentiality of the person reporting the suspected wrongdoing will be maintained. 

It is not possible to set a specific timeframe for completion of investigations in advance, as the diverse nature of potential disclosures makes this unworkable. Most investigations will be managed internally but we may appoint an external investigator or investigating team if we think it appropriate.

When the investigation is complete, both the person who reported and the individual to whom the issue was raised will be informed of the findings of the investigation.

The duties of the investigating manager/team have been outlined in detail in the section named Management of Investigations

Step 4: Disciplinary Action

If after the investigation is complete and it is discovered that the matter has not been reported in good faith, there may be disciplinary action taken on the person who raised the concern.

Any person found to be involved in any wrongdoing after conclusion of the investigation may have their contract terminated. Where it is believed that criminal activity has taken place, the matter may be reported to the police and appropriate legal action taken. 

Step 5: Completion of procedure

Details from the report as per the investigation will be used to minimise the risk of further wrongdoing, to prevent any further loss of assets, damage to reputation and to protect all sources of evidence.

This could be through strengthening of current processes and policies to improve the efficiency of both the third party and our company.