Whistleblower Policy

1. Objective

The objective of the Whistleblower Policy is to encourage and facilitate the reporting of unethical, illegal, or inappropriate conduct within Vertotech Aerospace Ltd. (hereinafter referred to as "the Company"). The Policy aims to protect whistleblowers from retaliation and ensure that reported issues are investigated and resolved in a fair and transparent manner.

2. Scope and Applicability

This Policy applies to:

  • All employees of the Company, including permanent, temporary, and contractual staff.
  • All individuals associated with the Company, including directors, contractors, and consultants.
  • The Policy covers all forms of unethical, illegal, or inappropriate conduct related to the Company’s operations.

3. Definition of Whistleblowing

Whistleblowing refers to the act of reporting concerns about actual or suspected unethical, illegal, or improper conduct within the Company. This includes but is not limited to:

  • Fraud or financial misconduct.
  • Corruption or bribery.
  • Violation of Company policies or regulations.
  • Safety or environmental violations.
  • Harassment, discrimination, or abuse.

4. Protection of Whistleblowers

a) Anonymity
  • Confidential Reporting: Whistleblowers may report concerns anonymously, although providing contact information may facilitate follow-up and resolution.
  • Confidentiality: The identity of whistleblowers will be kept confidential to the extent possible, and information will only be disclosed on a need-to-know basis.
b) Protection Against Retaliation
  • Zero Tolerance: The Company has a zero-tolerance policy for retaliation against whistleblowers. Retaliatory actions, including adverse employment actions, harassment, or discrimination, will be considered a serious violation of this Policy.
  • Reporting Retaliation: Whistleblowers who experience retaliation are encouraged to report it immediately to the designated authority.

5. Reporting Procedure

a) Channels for Reporting
  • Internal Reporting: Whistleblowers can report concerns to the Internal Complaints Committee (ICC), the Whistleblower Officer, or via designated reporting channels such as email or a hotline.
  • External Reporting: Whistleblowers may also report concerns to external regulatory authorities if internal channels are not appropriate or effective.
b) Procedure
  • Submission: Reports should be submitted in writing, including as much detail as possible about the concern, including relevant dates, names, and supporting evidence.
  • Acknowledgment: The Company will acknowledge receipt of the report within [insert time frame] and will provide updates on the status of the investigation as appropriate.

6. Investigation and Resolution

a) Investigation Process
  • Initial Assessment: The ICC or designated authority will conduct an initial assessment of the reported concern to determine if an investigation is warranted.
  • Investigation: If warranted, a thorough and impartial investigation will be conducted by qualified personnel. The investigation will involve gathering evidence, interviewing relevant parties, and reviewing documentation.
b) Resolution
  • Findings: Based on the investigation, the ICC or designated authority will prepare a report with findings and recommendations.
  • Action: Appropriate actions will be taken based on the investigation’s findings, which may include corrective measures, disciplinary actions, or changes in policies or procedures.

7. Roles and Responsibilities

a) Board of Directors
  • Oversight: Provide oversight of the Whistleblower Policy and ensure its effectiveness.
b) Internal Complaints Committee (ICC)
  • Implementation: Implement the Whistleblower Policy, handle reports, and oversee investigations.
  • Confidentiality: Maintain confidentiality and protect the identity of whistleblowers.
c) Whistleblower Officer
  • Support: Provide support to whistleblowers and handle the administrative aspects of the reporting process.
d) Employees
  • Compliance: Adhere to the Whistleblower Policy and report any concerns about unethical or illegal conduct.

8. Training and Awareness

  • Training Programs: The Company shall provide training on the Whistleblower Policy and procedures to all employees to ensure awareness and understanding.
  • Updates: Communicate any updates or changes to the Policy to all employees.

9. Documentation and Records

  • Records: Maintain records of reported concerns, investigations, and actions taken. All records will be handled confidentially and securely.
  • Retention: Retain records for a period of [insert time frame] or as required by applicable laws.

10. Policy Review and Amendments

  • Periodic Review: The Whistleblower Policy shall be reviewed periodically to ensure its effectiveness and compliance with legal requirements.
  • Amendments: Any changes to the Policy shall be approved by the Board of Directors and communicated to all employees.

11. Disclosure

The Company shall disclose the Whistleblower Policy in the Annual Report and on its website, as required by applicable laws and regulations.

12. Conclusion

Vertotech Aerospace Ltd. is committed to maintaining the highest standards of integrity and transparency. The Whistleblower Policy is designed to provide a safe and confidential mechanism for reporting unethical or illegal conduct and to ensure that all concerns are addressed promptly and fairly.

Date of Adoption: [Insert Date]

Approved by: Board of Directors, Vertotech Aerospace Ltd.