Introduction
Rosetti Pivot Limited (RPL) is committed to the highest standards of integrity, transparency, and ethical conduct. This Whistleblower Protection Policy provides a structured framework for employees, contractors, and stakeholders to report concerns regarding unethical, illegal, or improper conduct without fear of retaliation. This policy is aligned with our Code of Ethics and Professional Conduct (RPL-PRO-LEG-01), and our HR Policy Manual (RPL-MAN-HR-01), which outline ethical principles and practices, grievance procedures, and disciplinary measures.
Purpose
The purpose of this policy is to:
- Encourage the reporting of unethical, illegal, or improper activities.
- Protect whistleblowers from retaliation, discrimination, or disadvantage.
- Provide a transparent, confidential, and secure mechanism for reporting concerns.
- Promote a culture of accountability and compliance with all applicable laws and regulations.
- Ensure all reports are handled professionally, promptly, and fairly.
Scope
This policy applies to all employees, contractors, vendors, and external stakeholders engaged with RPL. It addresses a wide range of misconduct, violations, and infractions, including but not limited to:
- Financial fraud, misappropriation of funds, and accounting irregularities
- Corruption, bribery, and conflicts of interest
- Harassment, discrimination, and workplace misconduct
- Occupational health and safety violations
- Environmental law breaches and regulatory non-compliance
- Violations of internal policies or statutory obligations
- Any attempts to conceal misconduct, violations, and infractions
For a more comprehensive list of reportable violations and infractions, please refer to the HR Policy Manual.
Whistleblower Definition
A whistleblower is any employee or stakeholder who, in good faith, reports misconduct, violations, or infractions to the designated authorities within RPL. The whistleblower is not responsible for investigating or determining the outcome of the report; this responsibility lies with the Compliance Office, Human Resources, and other relevant management personnel designated to handle such matters.
Reporting Mechanisms
Whistleblowers are encouraged to report concerns through the following secure and confidential channels:
- Direct Reporting: Line Managers, Human Resources & Admin Manager, or Compliance Officers.
- Online Submission Portal: www.rosettipivot.com
- Secure Email: speakfreely@rosettipivot.com
Reports may be submitted anonymously, and all communications will be handled with the highest level of confidentiality to protect the identity of whistleblowers.
Anti-Retaliation Safeguards
RPL enforces a strict non-retaliation policy, prohibiting any form of retaliation, including victimization, harassment, or adverse employment action, against individuals who report concerns in good faith. Any retaliatory behavior will result in stringent disciplinary measures, up to and including termination. Employees who believe they have been subjected to retaliation should report their concerns to the Human Resources & Admin Manager immediately.
Investigative Procedures
All whistleblower reports will be acknowledged within five (5) business days.
The Compliance Office and Human Resources will conduct a preliminary assessment to determine the credibility of the allegations and whether a formal investigation is warranted.
Investigations will be conducted impartially, ensuring confidentiality and adherence to procedural fairness principles.
Based on the investigation findings, appropriate corrective actions—including disciplinary measures, process enhancements, and legal remedies—will be implemented as necessary.
Confidentiality and Data Protection
All whistleblower disclosures will be treated with the highest degree of confidentiality. Access to sensitive information will be strictly limited to authorized personnel on a need-to-know basis. Any personal data and relevant information collected during the investigation will be processed in full compliance with applicable data protection laws and corporate data protection policies and procedures.
False or Malicious Allegations
Knowingly submitting false, misleading, or malicious reports constitutes a violation of this policy and may lead to disciplinary or legal consequences. However, individuals who report concerns in good faith, even if the allegations are ultimately unsubstantiated, will be fully protected under this policy.
Review and Amendment
This policy will be reviewed to ensure its continued effectiveness, relevance to evolving legal and regulatory frameworks, and alignment with best practices in corporate governance and ethical compliance. Any updates will be communicated to all employees and stakeholders, who are required to familiarize themselves with any amendments.
10th of January 2025
