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Whistle Blower Policy

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Introduction:

‘Whistleblowing’ is a term used when an individual becomes aware of or suspects an act of misconduct within an organisation and makes a disclosure to report their concerns in accordance with “The Whistle blowers Protection Act, 2014”.

Fedstan GMC is committed to the highest potential standards of honesty, integrity and accountability. Fedstan GMC, encourage employees and others with thoughtful concerns about any facet of the effort and services to come forward and voice those concerns.

Policy purpose and principle:

This policy aims to encourage Fedstan GMC personnel and somebody who is connected to Fedstan GMC activities to raise concerns and in the right way, to the right people, at the right time, in line with "The Whistle blowers Protection Act, 2014". This offers 'whistle-blowers' constitutional protection from discharge or victimisation, resulting from their reporting a criminal offence, failure to comply with a legal obligation, miscarriage of justice, breach of health & safety rules, data privacy violation, damage to the environment or the deliberate act of disguising any of the above.

Any concerns raised including concerns about abuse or qualifying disclosures under the Whistle blowers Protection Act will be investigated promptly and systematically. Fedstan GMC's whistleblowing policy is intended to cover concerns that includes possible accounting or financial reporting violations, insider trading, leak of unpublished price sensitive information, bribery, or violations of the anti- retaliation aspects of this Policy.

This policy does not cover personal grievances or private disputes between personnel, and Fedstan GMC, such as failure to gain promotion, industrial injury compensation, disciplinary hearings, harassment or unfair treatment. These are enclosed by separate policies within the Fedstan GMC. For further guidance, please connect Fedstan GMC's Human Resource team.

Policy pertains to:

Fedstan GMC's whistle blowing policy applies to all Directors, employees or any other person including vendors, contractors, subcontractors, consultants, trainees, interns, shareholders, former employees, job applicants and any other third parties (collectively referred hereinafter as "Person(s)") must be able to raise concerns regarding such potential violations easily and free of any fear of retaliation.

However, to ensure a reasonable and detailed investigation, it may be essential to reveal the basis of the information during the process. Declarations by the individual may also be mandate as part of the evidence. Any related investigation correspondence and conversations will be treated in accordance with Digital Personal Data Protection Act (DPDPA) 2023, compliance.

How to escalate a concern?

Reporting is vital for timely detection, appropriate investigation and remediation, and prevention of violations of Fedstan GMC's policies or applicable laws. "Person(s)" should not fear for any undesirable consequences for reporting reasonably alleged violations because retaliation for reporting distrusted violations is strictly prohibited by Fedstan GMC's policy. Failure to report any reasonable certainty that a violation has occurred or is occurring is itself a violation of this Policy and such failure will be addressed with appropriate disciplinary action, including possible termination of employment or service from Fedstan GMC.

As an initial instance, you should raise your concerns directly with the Fedstan GMC’s, GRC compliance team via grc@fedstangmc.com who will treat the matter in conidence.

In what way Fedstan GMC will respond?

The action taken by the Fedstan GMC will depend on the nature of the concern. The matters raised may:

  • Internal Investigation Committee.
  • Referred to regulatory controls.

In addition to the protection afforded by the Fedstan GMC, disclosures as outlined above are also protected by the “The Public Interest Disclosure and Protection of Informer Resolution, 2004” and, in certain circumstances, the whistle-blower may also make a protected disclosure to Fedstan GMC authorised Legal Advisor.

An employee who makes an external disclosure will be protected if they have previously raised the matter with the Fedstan GMC, or they have not done so because they reasonably believe that they will be victimised or that the evidence will be concealed or destroyed. The disclosure must be made in good faith, in the reasonable belief that the accusations are substantially true and must not be made for personal gain.

The Fedstan GMC encourage anyone with serious concerns to share these details as anonymous allegations may limit ways to fully investigate the matter. If we receive an anonymous allegation, this will be considered at the discretion of the Fedstan GMC. In employing this discretion, the following factors would be considered:

  • Significance of the concern raised.
  • Reliability of the concern.

Further information, autonomous advice and Concern at Work can be contacted thru’ e-mail: grc@fedstangmc.com