Whistleblower

Whistleblower Manual and Procedure

In an era characterized by rapid technological advancement and unprecedented interconnectivity, the imperative for organizations to uphold unwavering standards of ethical conduct has never been more pronounced. The fabric of trust that binds Oben Technology to its stakeholders is meticulously woven from the threads of integrity, transparency, and collective accountability. Recognizing the intricate interplay between individual actions and the broader institutional ethos, we have endeavoured to construct a robust framework that not only delineates the expectations of honourable behaviour but also actively empowers every member of our extended community to serve as vigilant custodians of our shared values.

The following Whistleblower Manual and Procedure embodies this commitment to principled governance. By articulating clear mechanisms for the confidential disclosure of unethical, unlawful, or questionable activities, we aim to foster an environment where concerns are not only heard but earnestly addressed, free from the specter of reprisal. This document serves as both a shield and a compass—offering protection to those who courageously speak out, while guiding the organization toward continual refinement of its practices and processes. It is an invitation to participate, collectively and conscientiously, in the ongoing stewardship of our organizational reputation and ethical legacy.

Empowering Integrity, Protecting Transparency

At Oben Technology, we strive to cultivate a culture of honesty, openness, and accountability. This Whistleblower Manual and Procedure is designed to empower employees, contractors, and stakeholders to report unethical, illegal, or suspicious conduct without fear of retaliation. This comprehensive guide outlines principles, protections, and step-by-step procedures to ensure reports are addressed thoroughly and sensitively.  

Introduction

Oben Technology’s reputation rests on the integrity and ethical conduct of everyone associated with our organization. As part of our commitment to high ethical standards, we have established this whistleblower process to encourage the reporting of any conduct that violates our policies, applicable laws, or ethical standards.

Scope

This manual applies to:

• All Oben Technology employees (full-time, part-time, and temporary)
• Contractors, consultants, and agents
• Suppliers, vendors, and partners
• Any individual working on behalf of, or with, Oben Technology

Definition of Whistleblowing

Whistleblowing is the act of reporting concerns about illegal, unethical, or improper conduct. Examples of reportable matters include, but are not limited to:

• Fraud, theft, or embezzlement
• Corruption or bribery
• Violations of laws, regulations, or company policies
• Harassment, discrimination, or abuse
• Unsafe workplace practices or conditions
• Conflicts of interest • Environmental violations
• Suppression or manipulation of information

Principles of the Whistleblower Policy

• Confidentiality: All reports and identities will be handled with the utmost confidentiality to protect whistleblowers from retaliation.
• No Retaliation: Oben Technology strictly prohibits retaliation against anyone who raises a concern in good faith.
• Good Faith Reporting: Reports must be made honestly and with reasonable belief in their accuracy.
• Impartiality: All investigations will be conducted impartially, without bias or presumption of guilt.
• Timeliness: All reports will be addressed promptly and thoroughly.

Whistleblower Rights and Protections

• Protection from dismissal, demotion, harassment, or any form of discrimination as a result of making a report in good faith.
• Right to confidentiality of identity and details of the report, to the extent possible and permitted by law.
• Right to receive updates on the progress and outcome of the investigation, subject to confidentiality requirements.
• If retaliation is experienced, whistleblowers should report this immediately, and Oben Technology will investigate and act accordingly.

Whistleblower Responsibilities

• Report concerns honestly, accurately, and in good faith.
• Cooperate fully with any investigation undertaken as a result of your report.
• Avoid making frivolous or malicious complaints, as these undermine the intent of the policy and may lead to disciplinary action.

What to Report

Whistleblowers are encouraged to report any conduct that:

• Violates local, national, or international laws and regulations
• Breaches company policy or code of conduct
• Risks Oben Technology’s reputation or the safety and wellbeing of any individual
• Represents a misuse of company resources or information

How to Report a Concern

Employees and stakeholders can report concerns by any of the following means:

• Direct Supervisor: Raise the concern with your direct supervisor or manager, unless they are implicated in the matter.
• Whistleblower Email: Send details of your concern to the designated whistleblower email address (transparency@oben.technology).
• Online Portal: Complete an anonymous form via the company’s secure online whistleblower portal.
• HR: Contact or Human Resources directly. Whistleblowers may choose to remain anonymous. However, providing contact information can help with follow-up and investigation.

What to Include in a Report

For effective investigation, include:

• A clear and detailed account of the concern
• Date(s), time(s), and location(s) of the incident(s)
• Names and roles of individuals involved
• Any supporting documents or evidence
• Names of potential witnesses

Whistleblower Investigation Procedure

1. Receipt of Report: The Compliance Officer or designated recipient acknowledges receipt of the report within 3 business days where possible.
2. Preliminary Assessment: The Compliance Officer reviews the information to determine if the concern falls within the scope of the whistleblower policy.
3. Planning: If warranted, an investigation plan is developed outlining objectives, methods, and timelines.
4. Investigation
5. Fact-finding interviews with relevant parties
6. Review of documentation and evidence
7. Engagement of external specialists, if necessary
8. Reporting: Investigation findings are documented in a confidential report, outlining facts, conclusions, and recommendations.
9. Decision and Action: Management reviews the report and decides on corrective measures or disciplinary actions, if necessary.
10. Feedback and Closure: Whistleblowers are informed of the outcome, to the extent permissible, and the case is formally closed.
11. Record Keeping: All reports and investigation materials are securely stored for a minimum period as required by law and company policy.
12. Anonymity and Confidentiality Oben Technology is committed to protecting the identity of whistleblowers. While anonymous reports are accepted, providing contact information facilitates a more thorough investigation. All information is handled confidentially and is only shared with individuals who need to know in order to investigate and resolve the concern.
13. Protection Against Retaliation Oben Technology enforces a strict non-retaliation policy. Any act of retaliation against a whistleblower is a serious violation and will result in disciplinary action, up to and including termination of employment or contract. Anyone experiencing or witnessing retaliation should report it immediately using the methods outlined above.
14. False or Malicious Reports The whistleblower policy is designed to protect those who report in good faith. However, deliberately false or malicious reports are not tolerated and may result in disciplinary action.
15. Reporting and Monitoring The Compliance Officer is responsible for monitoring whistleblower reports, maintaining records, and providing regular anonymized updates to the Board of Directors. Annual reviews of the whistleblower program will be conducted to ensure effectiveness and identify areas for improvement.

Training and Communication

Oben Technology will provide mandatory training on whistleblower policies and procedures to all employees and relevant stakeholders. Ongoing communication will reinforce the importance of ethical conduct and reporting mechanisms.

Frequently Asked Questions (FAQ)

• Q: Can I report anonymously? A: Yes, anonymous reports are welcome and will be investigated with the same attention as identified reports. • Q: What if my supervisor is involved in the wrongdoing? A: If your supervisor is implicated, use one of the alternative reporting channels outlined above.

• Q: How long does an investigation take? A: Investigation duration depends on the complexity of the concern, but Oben Technology aims to address reports as promptly as possible.

• Q: Will I be informed about the outcome? A: Yes, whistleblowers will receive feedback, within legal and confidentiality limits.

Review and Updates

The whistleblower manual and procedures will be reviewed annually, or as necessary, to ensure alignment with best practices, legal requirements, and organizational changes.

Contact Information

For questions about this policy or to seek guidance, contact:

• Human Resources Manager
• Designated confidential email address (transparency@oben.technology)

This manual is an integral part of Oben Technology’s commitment to ethical conduct, transparency, and the protection of all individuals who speak up in good faith. By adhering to these procedures, we safeguard not only our company’s reputation but the trust of our employees, partners, and community.