1st Principle: Easy Access
· As a matter of principle, potential Whistleblowers report a Concern to the Board Audit, Risk & Compliance Committee (BARCC) via the (Chief Internal Audit) who acts as a Whistleblowing Reporting Officer. Whistleblowers have the right to consult the Reporting Officer before reporting a Concern.
2nd Principle: Anonymous Access
· Whistleblowers are encouraged to disclose their identity when reporting a Concern.
· However, if the Whistleblower only feels able or comfortable to report a concern if made anonymously, then the Whistleblower can report the Concern Anonymously to firstname.lastname@example.org This email account will only be accessed by the Chief Internal Auditor in his capacity as Whistleblowing Reporting Officer and the members of the BARCC.
3rd Principle: Confidential Identity
· As a matter of principle, the identity of a Whistleblower who has not reported anonymously is only known to the Reporting Officer receiving the reported Concern and is not disclosed to anyone else unless:
· It is strictly necessary for one or more of the legally Authorized Persons to know;
· EDB is legally obliged to disclose a Whistleblower's identity; and/or
· The disclosure of such information is required when EDB decides to report to relevant regulatory or criminal authorities.
4th Principle: No Right to Immunity
· Whistleblowers reporting a concern whose own conduct is implicated in the concern will not be given any automatic immunity from Investigation, disciplinary action, criminal prosecution and/or civil liability.
· The same applies to any other stakeholder who provides information, who causes information to be provided, or who otherwise assists in an Investigation.
1st Whistleblowers must:
· Consider using normal reporting channels before reporting a Concern.
· Consider reporting to His/her Line Manager before using an Alternative Channel. In case of external stakeholder, to report to EDB management.
· Report a Concern in Good Faith.
· Provide all relevant information.
· Be available to the Reporting Officer for an Investigation.
· Respect Confidentiality.
2nd Reporting Channels
· Stakeholder are encouraged to report any Concerns through the normal reporting channels (i.e. through their immediate or next higher-level manager in case of employees, or EDB Management in case of external parties) in order to keep an open dialogue.
· If a stakeholder feels unable or uncomfortable raising the Concern through the normal reporting channels, the stakeholder is then encouraged to report the Concern to EDB’s Reporting Officer. As such, this complements the normal reporting channels.
3rd Providing Information / Availability to the Reporting Officer
· Whistleblowers are requested to provide information at hand and all known details about the event(s) underlying the Concern, such as:
1- The date of the event(s);
2- The nature of the event(s);
3- The name of the person(s) involved in the events;
4- (Possible) witnesses to the event(s);
5- Evidence of the event(s) if any.
4th Respect Confidentiality
· A Whistleblower is encouraged to report and provide new or additional details of the Concern to the Reporting Officer only. The Reporting Officer is responsible for forwarding new or additional details to the appropriate Authorized Persons on a strict 'need to know' basis.
· Neither a Whistleblower nor any other Employee who provides information, allowed to discuss the details of the reported Concern or involved in any related Investigation.